INTERNET ACCESSPROVIDERSHOSTINGPROVIDERS

Child sexual abusematerial and online
terrorist propaganda
Tackling illegal content
and ensuring staff welfare

AUTHORITIESREGISTRARSPLATFORMS

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TABLE OF CONTENTSFOREWORD — PURPOSE AND SCOPE.................................................................. 2I) RECEIVING REPORTS..................................................................................................... 3A) The reporting mechanism.............................................................................................. 3a) Setting up a reporting tool..................................................................................................... 3b) Receiving reports........................................................................................................................ 4B) Assessing content................................................................................................................. 4a) Assessing child sexual abuse material........................................................................... 4b) Assessing terrorist propaganda.......................................................................................... 6II) PROCESSING REPORTS.............................................................................................. 8A) Forwarding reports to the authorities................................................................... 8a) PHAROS: the national portal to report illegal online content.......................... 8b) Follow-up of reports.................................................................................................................. 9
Flowchart............................................................................................................................................ 10B) Applicable actions and time limits......................................................................... 11
III) STAFF WELFARE........................................................................................................... 12
A) Setting up the workplace environment and establishingworking conditions................................................................................................................... 12a) Workplace environment....................................................................................................... 12b) Working conditions................................................................................................................. 12B) Psychology at the heart of the job............................................................................ 13a) Prior psychological assessment:a desirable procedure before starting in the role.................................................... 13b) Psychological follow-up throughout the working period ................................ 14c) Final assessment upon leaving the job......................................................................... 15
Insights from a specialised psychologist................................................................. 16
ANNEX: RESOURCES......................................................................................................... 17
Legal definition and the fight againstchild sexual abuse material (CSAM)................................................................................... 17
Documentation on terminology........................................................................................... 17
Other handbooks on best practices..................................................................................... 17
Editorial Board............................................................................................................................ 18

FOREWORD - PURPOSE AND SCOPE

FOREWORD – PURPOSE AND SCOPE
This white paper aims to develop a shared set of best practices pertaining to the operational handling and processing of harmful and potentially illegal
content, which may endanger the physical safety and psychological wellbeing ofprofessionals.
The illegal and harmful content mentioned here refers to two separate
categories: Child Sexual Abuse Material1 (article 227-23 of the French Criminal
Code) and content which incites or advocates committing terrorist offences (article
421-2-5 of the French Criminal Code).
While there has been a continuous growth in the distribution of and accessto such content since the 1990s, one can only observe that there has been an
acceleration since 2010, with the spread of connected devices (tablets, smartphones, smart TV sets, video game consoles) and high-speed, mobile broadband
networks.
Therefore, these past few years, the number of individuals tasked withhandling and processing such content worldwide has grown exponentially, reaching several thousand today. Small and medium enterprises (SMEs), as well aslarger corporations, are compelled to be equipped with services dedicated tothis activity. Even if technology and artificial intelligence boost the effectivenessof these professionals, the sheer complexity of content assessment and the very
issue of protecting people from harm continue to stress the necessity of humanintervention.
The present handbook is aimed at professionals from companies which
publish and distribute online content, hosting providers and platforms, social
media, domain name registrars, Internet access and service providers, law enforcement authorities as well as all staff members whose responsibility and function
is to tackle illegal content resulting from cybercrime activities.
The protection of victims who appear in such content, as well as the protection of individuals who may be targeted by such content, call for the intervention of qualified professionals. This is precisely why it is essential to come up witha shared set of best practices to strengthen the effectiveness of reporting loops.
Harmful content may affect all those who are exposed to it in their professional capacity, whether on a regular or periodic basis. Because those professionals make up an essential first line of defence, this white paper intends to contribute to acknowledge their role and the necessity to take steps to ensure theirwelfare.
1

We prefer the use of the term Child Sexual Abuse Material abbreviated as CSAM to refer to content

elsewhere referred to as ‘child pornography’. The use of the term “child pornography” in relation to children
is criticised, as “pornography” is a term primarily used for adults engaging in consensual sexual acts, insteadof highlighting the fact that children are victims of sexual abuse and/or sexual exploitation. The term “childsexual abuse material” (CSAM) is increasingly being used to replace the term “child pornography” highlighting
the fact that children are victims and that the acts are carried out without their consent/responsibility. For more
information regarding terminology, see resources in the annex of this document.

2

RECEIVING REPORTS

3I) RECEIVING REPORTS
The French Law regarding Trust in the Digital Economy (La loi pour laconfiance dans l’économie numérique, LCEN)2 stipulates that all hosting providers, whether natural persons or legal entities, should contribute to the fightagainst content which incites or advocates committing terrorist offences, as well
as child sexual abuse material, as types of illegal and harmful content.
The primary positive obligation which relies upon them may be found atarticle 6 – I, paragraph 7:“[…] As such, they must put in place a visible and easy-to-access reporting
tool which allows any person to bring to their attention the existence of suchcontent. They also have the obligation, on the one hand, to promptly informthe competent public authorities of all illicit activities mentioned in the previous
paragraph, should they be reported to them […]”A) The reporting mechanisma) Setting up a reporting tool
The first obligation is to provide the public with an easy-to-access online
reporting tool so it takes no more than a few clicks to fill out and complete thecomplaint form. To this end, a dedicated, simple, easily identifiable and free ofcharge reporting mechanism should be set up. Publicly accessible content should
be reported without having to create an account. It is also recommended to offer
Internet users the possibility to report content anonymously.
A reporting mechanism is often materialised by an email address e.g.
abuse@example.tld or, via a dedicated online form. For edited content on platforms, Internet users should be able to report suspected illegal content at any
time throughout their browsing session on the platform.
It is strongly advised that the reporting channel be entirely and solely dedicated to this use in order to separate this information from other exchanges (e.g.
requests directed to the sales department, consumer complaints, enquiries).

2

https://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000000801164

RECEIVING REPORTS

4b) Receiving reports
Receiving and handling potentially illicit content should only be reserved for authorised employees tasked with content assessment. Likewise, other
employees who are not assigned with content assessment should not be exposed
to such content. Reviewing such content absolutely requires the prior consent of
the affected employee(s) and should under no circumstances be imposed uponthem arbitrarily.

B) Assessing contenta) Assessing child sexual abuse materialChild sexual abuse material and its online distribution3 are referred to inarticle227-23 of the French Criminal Code. Paragraph 1 stipulates:“Taking, recording or transmitting an image or representation of a minor witha view to circulating it, where that image or representation has a pornographic
character is punished by five years of imprisonment and a fine of 75,000 euros.
When that image or representation regards a minor under fifteen years of age,these offences are punished, even if they were not committed with a view tocirculating the image or representation.”

Paragraph 1 specifies the content referred to as depicting minors, that is
to say any person under the age of eighteen. While determining if a person is aminor is in general not difficult, the distinction between a minor and an adult is notalways obvious, especially for adolescents.4
The French legislation does not distinguish between real or virtual content(e.g. drawings, photomontages or photoshopping). In France, only fictional text
describing child sexual abuse or advocating paedophilia is not covered by law.
The content must be of sexual nature. This excludes a priori from theformer images of nudism or naturism, as well as images of naked or semi-naked
children in a non-sexualised context. By contrast, this includes all images of children, naked or clothed, where the analysis of the wider context, the characteristicsof the shooting, specific focus on certain parts of the body, the child being madeto pose in an inappropriate way, or toys or objects suggesting a sexually explicit
setting may guide the assessment.
Therefore, by considering the context, an image depicting a naked child
may be legal while an image depicting a clothed child may be illegal.

3

Art 227-23 al.2: “The penalties are increased to seven years of imprisonment and fine of 100, 000 euros

when use was made of a communication network for the circulation of messages to an unrestricted public inorder to circulate the image and representation of a minor.”4

For further information, The Tanner scale provides a classification of the various stages of puberty

development.

RECEIVING REPORTS

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The last paragraph of article 227-23 makes the following clarification:“The provisions in the present article shall also apply to pornographic images ofany person whose physical appearance is that of a minor, unless it is proven thatthe person was over eighteen years of age on the day the image was taken orrecorded.”

The article stipulates that images of a person whose physical appearance
is that of a minor should also be subject to the full force of the law. What is relevant here is visual depictions that “appear to be” of minors. When in doubt as
per the age of the depicted person, it is advised to report the content.
French law does not provide an accurate definition of what is meant by animage or representation of ‘pornographic nature’ of a minor, but other sources5
might prove insightful in this regard.
Directive 2011/93/EU6 of the European Parliament and the Council of 13
December 2011 states in its definitions reported in Article 2:“[…] c) ‘child pornography’ means:i) any material that visually depicts a child engaged in real or simulated sexually
explicit conduct;ii) any depiction of the sexual organs of a child for primarily sexual purposes;iii) any material that visually depicts any person appearing to be a child engaged
in real or simulated sexually explicit conduct or any depiction of the sexual organsof any person appearing to be a child, for primarily sexual purposes; oriv) realistic images of a child engaged in sexually explicit conduct or realistic
images of the sexual organs of a child, for primarily sexual purposes; […]”b) Assessing terrorist propaganda
The first two paragraphs of article 421-2-5 of the French Criminal Codeaddress the legal framework and scope of the offences:“Directly inciting to the committing of terrorist acts or publicly advocating
the committing of such acts are punished by five years of imprisonment and afine of 75,000 € . The punishment shall be seven years of imprisonment witha fine of 100,000 € if the offences are committed while using an online public
communication service.”

5

To help you in assessing child sexual abuse material, you may find useful sources and links listed in theannex of the present document.
6

https://publications.europa.eu/en/publication-detail/-/publication/d20901a4-66cd-439e-b15e-

faeb92811424/language-enRECEIVING REPORTS

How to comprehend what does or does not qualify as incitement to terrorism or advocacy of terrorism?
The official website of the French public administration sheds light on thematter in a factsheet covering such offences:7“Advocacy/glorification of terrorism
Advocacy or glorification of terrorism consists in presenting or commenting
favourably on terrorist acts which have already been committed. For instance, if aperson approves of a terrorist attack.
Advocacy or glorification differs from terrorism denial. Denying terrorist acts iswhen a person partially or completely denies these acts ever took place, without
directly condoning them. For instance, if the person invokes a conspiracy.
To be punishable by law, advocacy or glorification means it was carried out publicly. The public nature of the statements may be assessed in the same way as fordefamation and insult. Therefore, comments made on publicly accessible social
media may be punished.
Incitement to terrorism
Incitement to terrorism means direct incitement or provocation to commit materially determined terrorist acts. For instance, to deliberately target a location ora well-known public figure. With regard to the context, the intentionality of theauthor and the chosen wording, such statements are intended to encourage andpersuade other people to commit such acts.
Here, it is a matter of incitement, encouragement to carry out acts of terrorist
nature in the future and not an endorsement and approval of terrorist acts whichhave already been committed.
Such statements do not need to have been made in front of a large audience.
Comments which may be read by a few friends on social media or made during a
private meeting may be punished.”

7

https://www.service-public.fr/particuliers/vosdroits/F32512

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RECEIVING REPORTS

Terrorist propaganda which does not include violent imagery may beillegal. The context has a bearing on the assessment. Researchers and journalists may use this kind of content to illustrate the findings of their investigations. It is therefore advisable to differentiate publications which are intended todenounce terrorist propaganda, which shall not be subject to the force of the law,from publications which are intended to promote terrorism, and which shall beclassified as incitement to or glorification of terrorism.
Besides, harmful content depicting scenes of brutal violence, and not
falling under the categories of incitement to or glorification of terrorism, may
nevertheless prove illegal, by constituting, for instance, a violation of humandignity.
Beyond direct incitement to committing acts of terrorism or the glorification of terrorist attacks which have already been carried out, anything which isintended to lead people to adopt the ideology of a given terrorist group, to join
their ranks, as well as any kind of publicity designed to promote it should also be
identified and assessed as illegal content.
Because of the language used in certain publications, it may at times be difficult to understand certain content and therefore assess it or determine whether
it is illegal. In such cases, it is highly recommended to report any content which
includes emblematic visual signs that directly link the content to a known
terrorist group, or one of its media.

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PROCESSING REPORTS

II) PROCESSING REPORTS
The mission of employees tasked with processing reports is to assess anddetermine whether the content is manifestly illegal according to French law. If theassessment seems obvious in many cases, certain content may raise questions.
When in doubt, it is advised to forward the reports to the competent authorities
who will proceed with assessing their legality, or to contact, for instance, the professional association Point de Contact,8 the private sector platform dedicated tothe processing of reports of suspected illegal online content.

A) Forwarding reports to the authoritiesa) PHAROS9: the national portal to report illegal online content
The second obligation for content hosting providers is to promptly inform
law enforcement authorities as soon as they are aware of manifestly illegal online
content hosted on their sites. The French LCEN does not impose upon the hosting
provider a general obligation of surveillance as per the information/data it transmits or stores10 but, as soon as the hosting provider becomes aware of the presence of a publication which is manifestly illegal on its sites, it should promptly
inform law enforcement authorities.
In order to receive reports and tip-offs from the general public andInternet stakeholders, the French authorities also set up a dedicated unit. Thus,
the PHAROS platform, staffed by gendarmes and police officers, was set up on
September 1st, 2006 within the OCLCTIC,11 France’s national cybercrime investigation unit, to ensure the judicial processing of the reports.
An online form12 has been made available to the public and allows anyone
to report suspicious online content or behaviour. Private entities can sign apartnership agreement with the platform to obtain a trusted flagger account.

8

https://www.pointdecontact.net/

9

In French, the acronym stands for Plateforme d’Harmonisation, d’Analyse, de Recoupement et d’Orientation

des Signalements (Platform for the Harmonisation, Analysis, Cross-checking and Orientation of Reports)
10 LCEN, article 6-1-7. “The persons mentioned in 1 and 2 are not subject to a general obligation of monitoring
the information they transmit or store, nor to a general obligation of looking for facts and circumstances thatreveal unlawful activities […]”
11 in French, the acronym stands for Office central de lutte contre la criminalité liée aux technologies del’information et de la communication (Central Office for Combating Information and Communication Technology
Crime)
12 https://www.internet-signalement.gouv.fr

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PROCESSING REPORTSb) Follow-up of reports
The PHAROS platform is the French authorities’ single entry point. Itsrole is to analyse and assess online offences, with further legal action for illegal
content. It redirects the reports towards the locally competent law enforcement
authorities, whether the police or the gendarmerie, or towards specialist services
depending on the nature of the content (C3N,13 OCRVP,14 etc.). For matters involving international cooperation, PHAROS works closely with INTERPOL.
Reports are not considered as complaints, but rather as tip-offs or leads.
They are used as the following procedure shows:• checking the existence of the reported content (is it still online?);• legal assessment (is it illegal according to French law?);• precautionary measures (e.g. content back-up and evidence archiving,enhancement and cross-checking of information, technical verifications, OSINT,15
image integration and image comparison in the CNAIP16 database, etc.), deciding upon the competent authority (if necessary, with additional investigative
capabilities);• start of an investigation.
OR• forwarding of reports to the competent authority, police or gendarmerie
unit, or to the competent authority abroad via INTERPOL;• start of an investigation by the competent authority;• follow-up (advice to the competent authority and feedback).
When content removal cannot be obtained, PHAROS has exclusive competence over administrative blocking17 for child sexual abuse material and terrorist propaganda, blocking all access to these publications via the French Internet
service providers. These measures are subject to oversight by the designatedperson of the French Data Protection Authority, the CNIL.18

13 The acronym stands for Centre de lutte contre les criminalités numériques (Central Unit for Fighting Digital
Crime), which operates within the French Gendarmerie.
14 https://www.police-nationale.interieur.gouv.fr/Organisation/Direction-Centrale-de-la-Police-Judiciaire/
Lutte-contre-la-criminalite-organisee/Office-central-pour-la-repression-des-violences-aux-personnes
15

Wikipedia: “Open-source intelligence (OSINT) is data collected from publicly available sources.”

https://fr.wikipedia.org/wiki/Renseignement_d%27origine_source_ouverte
16

In French, the acronym stands for Centre National d’Analyse d’Images Pédopornographiques (National

Centre for the Analysis of Child Sexual Abuse Images)
https://www.gendarmerie.interieur.gouv.fr/Zooms/Cybercriminalite
17 https://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000029754374&categorieLien=id
18 https://www.cnil.fr/fr/controle-du-blocage-administratif-des-sites-la-personnalite-qualifiee-presente-son3eme-rapport

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INTERNET ACCESSPROVIDERSHOSTINGPROVIDERSREGISTRARSPLATFORMS

Notification

Assessment by a specialised officer

In doubt over the assessment

Not illegal

IllegalForward to Point de Contact

Matter not pursued

Forward to PHAROS

Assessment

Not illegal

IllegalMatter not pursued

Forward to PHAROS

PROCESSING REPORTS

B) Applicable actions and time limits
When manifestly illegal content is reported to the hosting service provider, it must, after assessment, expeditiously notify the competent authorities andforward it to them. Then, it must disable the online content from public access,while allowing sufficient time for police investigations and digital forensics.
It is advised to indicate the date and time by which the suspension will takeplace. If possible, it is recommended to set up a dedicated offloading space, topreserve the content during the time necessary for the investigation.
The content should therefore be suspended or made inaccessible, butshould certainly not be deleted. Such a procedure is subject to the relevant
criminal penalties, as per the article 434-4 of the French Criminal Code.19 The
hosting provider could be accused of destroying evidence and jeopardising theongoing investigation.
It should be noted that it is right from the beginning, from the very firsthours of online presence, that such content is most harmful, due to how quickly it
spreads.

19 Article 434-4 of the French Criminal Code: “Where it is done to in order to obstruct the discovery of truth,a penalty of three years of imprisonment and a fine of 45,000 euros applies to:
1° Modifying the scene of a felony or misdemeanour either by the alteration, falsification or obliteration of clues
and evidence, or by bringing, removing or suppressing any given object;
2° Destroying, purloining, concealing, or altering a private or public document or an object to facilitate thediscovery of a felony or misdemeanour, the search for evidence or the conviction of the guilty party.
Where the acts provided for under the present article are committed by a person who, because of their position,is called to take part in the discovery of the truth, the penalty is increased to five years of imprisonment and afine of 75,000 euros”

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STAFF WELFARE

III) STAFF WELFARE
Exposure to such content requires a suitable working space set-up, appropriate working conditions, and psychological assessments to protect professionals
and help them safeguard their personal wellbeing.

A) Setting up the workplace environment and establishingworking conditionsa) Workplace environment
Processing such content requires a specific set-up and configuration of theemployee’s workstation. Employees who are not authorised to view content, andother people who might be in the premises, should in no circumstances be able toaccess, view nor hear such content.
Computers which are used for content assessment should, by default, beprotected by complex and not accessible passwords. Besides this security procedure, it is highly recommended to have these computers encrypted. In addition, it
is advisable to attach privacy filters to computer screens and position them so as
to avoid any kind of content exposure to other employees. The use of headphones
is also recommended to assess video sound, if necessary.
The facilities, or dedicated spaces, should also be signalled by a warning
sign to prohibit entry to unauthorised personnel.
If remote work is on the rise and trending,20 it is nonetheless strongly inadvisable to review and assess content outside facilities intended for this purpose.
To associate one’s home with an environment of violent imagery would be harmful
and prejudicial to the employee and their loved ones.
Protecting the outside environment from exposure to content is also ameasure which should be considered. Windows may be fitted with opacifying
panels if the working space can be seen from the outside.
Nevertheless, and despite these set-up and configuration constraints, it
must be ensured that professionals are not further isolated, so they do not feel
excluded from the organisation’s work environment.

b) Working conditions
The professional who assesses such content should not work alone in theoffice. Isolation can increase the stress related to content exposure.

20 https://www.legifrance.gouv.fr/affichCodeArticle.do?cidTexte=LEGITEXT000006072050&idArticle=
LEGIARTI000025558060

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STAFF WELFARE

The professional should be able to go for a break whenever they feel theneed for it, when working on content assessment, so they can unwind, step backand distance themselves from content which might have shocked them.
It is recommended to set up a relaxation area in the office, outside thecontent assessment area, so one can more easily extract oneself from the content
related environment. Certain entities provide video game consoles, board games,
table football, TV, reading materials or offer sports and cultural activities.
The employee should be able to talk to their manager when needed or any
competent person within the structure. It is advised to have regular team meetings during which working conditions may be re-evaluated.

B) Psychology at the heart of the job
The effects of this type of jobs on one’s psychological health are often
downplayed by the exposed personnel for reasons of pride, modesty, self-neglect
or by a lack of awareness of the insidious effects of dealing with such harmful
content.
Important: for the company or the public entity, generalisations orassumptions based upon one’s age, gender or known marital and family status
should not be made as per the ability of a person to deal with such content. There
are no rules in terms of psychological resilience. For all individuals, the risks, suchas psychological fatigue, are real and should be taken seriously, irrespective of thefrequency or degree of exposure.

a) Prior psychological assessment: a desirable procedure before
starting in the role
Protecting staff also means ensuring their ability to endure exposure tosuch content. It is highly recommended to have the candidate or employee considered for a job with such exposure undergo a psychological assessment.
Prior psychological assessment must be carried out by a clinical psychologist or a recruitment psychologist. The purpose of the assessment is to evaluate the awareness of the candidate as per their future duties and their potential
consequences on their psychological wellbeing, as well as to judge their ability
to work in the prolonged presence of potentially traumatic content. The psychologist’s opinion should not bind the decision of the recruiter but may guide it.
It should also be noted that prior psychological assessment may be valid in the
moment and not prejudge psychological change which may be observed at alater stage in subsequent sessions.
Important: the in-house transfer towards a role as specific and particular
as a content assessment one should always be consented to by the colleague,
who must understand the range and risks of the job, and fully comprehend therecommendations to protect oneself.

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STAFF WELFAREb) Psychological follow-up throughout the working period
Once the person is hired, it is highly advised to set up compulsory psychological follow-up that only a clinical psychologist can carry out. The occupational
psychologist specialised in the prevention of psychosocial risks may assist, forprevention purposes, the head of the department or the organisation in taking
into account the situation at hand. The frequency of the mandatory psychologicalassessments should exceed one session per year.
On top of this mandatory follow-up, the exposed professional should haveaccess to counselling when needed, without the employer’s prior consent. The
cost of these counselling sessions should be entirely covered by the company. All
staff members, irrespective of their seniority and length of service, should benefit
from the same follow-up.
A request for a counselling session should never be used to doubt theability of the professional to perform their duties. The session should be confidential to allow for open dialogue between the employee and the entity in charge ofthe psychological follow-up. However, the psychologist in charge of the follow-up
should be able to alert the organisation when there is a risk for the professional or the organisation, while respecting the confidentiality of the sessions. At aminimum, the psychologist should be able to alert the organisation via the occupational physician of the need to review how content is being processed as well
as of the necessity to pay attention to the psychological health of the exposed
personnel. The psychologists in charge of the follow-up of these personnel shouldmake sure all steps and measures are taken to ensure their support and protection.
It may occur that a professional is unable to find themselves in need of
psychological help or that they do not sufficiently take into account the risks that
their state might generate. It may be considered useful to heighten the awarenessof the line managers as per the detection of early signs of psychosocial risks, possibly with the help and intervention of an occupational physician.
Group counselling sessions might also prove highly valuable to improve
teamwork and build shared awareness.
Important: requesting a counselling session outside the mandatory follow-up should never be perceived as a sign of weakness or an indicator of unsuitability for the job. On the contrary, the professional who knows how to identify
when their wellbeing might be threatened, and who takes the initiative to avoid
related risks, is much more equipped to carry out their duties in good conditions
than the person who chooses not to divulge the encountered difficulties.

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STAFF WELFAREc) Final assessment upon leaving the job
When a professional ends their work period in the presence of child sexual
abuse content and/or images of scenes of terror, it will not mean that the images
and videos they were exposed to will leave their mind. The professional may haveexperienced episodes of psychological fatigue which, if left insufficiently treated,
could well persist after the end of their contract. Profound alteration may havetaken place in terms of moral, philosophical, spiritual or political representations
and conceptions. It is advised to carry out a psychological assessment when theprofessional leaves their job. This assessment should allow the professional totake stock of this professional experience, to mention what may have affected
them in both professional and private spheres, and to detect any consequences it
may have had on them. The psychologist should be able to provide guidance as
per dealing with potential difficulties, or respond to certain questions, which may
remain or resurface in the future.

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STAFF WELFARE

Insights from a specialised psychologist
Psychological aspects of the professional viewing child sexual
abuse images
By Jean-Baptiste Colle
Graduate from the French School of Practising Psychologists,
specialised in criminology, psychotrauma and child protection.
In charge of psychological follow-up for the association Point deContact from 2014 to 2018.

«

Viewing images or videos of child sexual abuse is never harmless. Within
the company, the person in charge of assessing such content should have volunteered and chosen, beforehand and out of free will, to carry out such a delicate
mission, be trained in content analysis, and receive throughout the process support from a colleague or a line manager. When dealing with such content, it is important that the individual is not alone and can talk to another colleague who will
be able to provide support, guidance and even assistance with filing the report.
When facing such imagery, the analyst may feel alternately confusion, fascination, astonishment, rejection, an absence of affect, anxiety, sadness, guilt,
shame, and even a profound questioning of one’s very own ideals and conceptions which guide both one’s inner world and outlook on society.
The confrontation with such raw, harsh images depicting child sexuality
takes us back to our representations of child and adult sexuality, as well as sexual
violence. We are not all equipped with the same mental and psychological resources, as per our history (past history of intra- or extra-familial sexual violence,
unsatisfying sexual experience…) as well as our current emotional and family life
(parent of young children, current pregnancy, going through a difficult patch…).
The analyst may at times feel useless, lonely, not feeling heard or understood, andthis, possibly in echo to the experience and feelings that a child victim or an adultsex offender could have.
Indeed, it is possible that a ‘transfer’ to or an ‘identification’ with one ofthe protagonists depicted in a video or an image may take place. This frequentmechanism, allowing the subject to ‘be in someone else’s shoes’, may be experienced with anxiety, and should be worked upon in a different space, with a
psychologist, to identify the emotions, thoughts and representations which thesubject associates with these images. This may also help the subject to understand the function of one’s job with regard to current society, distance oneself, as
well as drawing a line between work and private life.

16«

ANNEX

17

ANNEX: RESOURCES
Legal definitions and the fight againstchild sexual abuse material (CSAM):
Convention on Cybercrime, (definition at article
9 §2), Council of Europe, 2001
http://www.europarl.europa.eu/meetdocs/2014_2019/documents/libe/
dv/7_conv_budapest_/7_conv_budapest_en.pdf
Convention on the Protection of Children from
Sexual Exploitation and Sexual Abuse (definitionat article 20 §2), Council of Europe, Lanzarote,
2007
https://rm.coe.int/protection-of-childrenagainst-sexual-exploitation-and-sexualabuse/1680794e97
The International Association of Internet
Hotlines, INHOPE:
http://inhope.org/gns/internet-concerns/overview-of-the-problem/child-pornography.aspx
The Internet Watch Foundation (IWF):
https://www.iwf.org.uk/what-we-do/
how-we-assess-and-remove-content/
laws-and-assessment-levels
Child Pornography: Model Legislation and
Global Review, ICMEC, 8th edition, 2016
http://www.icmec.org/wp-content/
uploads/2016/02/Child-Pornography-ModelLaw-8th-Ed-Final-linked.pdf
Crimes against children - INTERPOL:
https://www.interpol.int/en/Crime-areas/
Crimes-against-children/Crimes-against-children

Documentation on terminology:
Terminology Guidelines for the Protection ofChildren from Sexual Exploitation and Sexual
Abuse, Interagency Working Group on Sexual
Exploitation of Children, 2016
http://luxembourgguidelines.org/
english-version/

Other handbooks on best practices:
MAAWG Disposition of Child Sexual Abuse
Materials Best Common Practices, Messaging
Malware Mobile Anti-Abuse Working Group,2015
https://www.m3aawg.org/sites/default/files/
document/M3AAWG_Disposition_CAM-201502.pdf
Staff Welfare Best Practice Paper, INHOPE 2013
http://hotlinedevelopmentguide.org/cms/
wp-content/uploads/2016/04/Best-PracticeStaff-Welfare-2013.pdf
Employee Resilience Guidebook for HandlingChild Sexual Abuse Images, The Technology
Coalition, 2013
http://technologycoalition.org/
wp-content/uploads/2013/05/
EmployeeResilienceGuidebook2013.pdf

18

The present document is an update provided by the French Association
Point de Contact of the Guide d’Usage pour la Lutte contre la Pédopornographie(A Professional Handbook on the Fight against Child Sexual Abuse Material),
drafted in 2014 upon the initiative of Alexandre Hugla, in charge of the anti-abusedepartment at Gandi.net.

Editorial Board :Quentin Aoustin,
Director of Operations,
Association Point de Contact

Thomas Fontvielle,
Secretary General, Signal Spam Association

Alexandre Hugla,
Philippe Baudoin,
Manager of the Anti-Abuse Department,
Colonel in the French Gendarmerie,Gandi.net
Adviser, French Ministry of the Interior – DMISC,
Ministerial Action Plan for Fighting Cyber Threats Jean-Christophe Le Toquin,
President, Association Point de Contact
Alexandre Archambault,
Attorney-at-Law, expert in ICT law
Nikoleta Lydaki Simantiri,
Legal Adviser – Analyst,
Adeline Champagnat,
Association Point de Contact
Chief Superintendent in the French Judicial
Police,Patrick Mariatte,
Central Directorate of the Judicial Police,
Chief Inspector in the French Police,
Adviser to the Delegation on Fighting Cyber
Head of the Internet Division, OCLCTIC,
Threats
France’s Central Office for Fighting ICT-related
Crime
Caroline Claux,
Captain in the French Gendarmerie,
Pauline Sêtre,Head of the Central Unit for Fighting Digital
Legal Adviser – Hotline Manager,
Crime (C3N),
Association Point de Contact
Criminal Intelligence Central Department (SCRC)
of the French Gendarmerie
Anne Souvira,
Cyber Lead, Office of The Prefect of Police,
Jean-Baptiste Colle,
Paris Police Prefecture,
Psychologist, graduate of the French School
French Ministry of the Interiorof Practising Psychologists, specialised incriminology, psychotrauma and child protection Sarah Jane Mellor,
Translation and adaptation
Alain Doustalet,
Anti-Abuse Desk Team Manager, Orange
Florence Esselin,
Expert adviser in digital affairs and cybersecurity,
Office of the Directorate-General of the French
Gendarmerie,
Digital Mission and Command of the National
Gendarmerie