So we did make a submission to the Digital Citizen Initiative last septmeber. This bill seems focused on Canadian content and french language inclusion...
but they are talking about the creation of a new regulator - Digital Commissioner - and advisory bodies etc.... all the things that could try to eliminate sex work from the internet...
we made a submission which is the following ( it also included a preamble about the human rights act which had been revised with additions but i cut it for posting here);
Establishment of new Regulators
Canadians agree that the current “wild west” status of the internet causes problems on many levels and that some form of regulation is required in order to protect people from all of the harms outlined in the proposed processes.
However, nowhere in the proposed mechanisms are sex workers or adult entertainers mentioned.
Given that a minimum of 100,000 ( up to approx. 250,000) Canadians rely on adult entertainment as their sole source of income to feed and house themselves and their families, consideration must be given to the perspectives and experiences of these workers and legal industry.
The adult entertainment community of workers and entrepreneurs are asking for the following additions and changes to the framework as outlined in both the Discussion document and Technical document;
Module 1(a) – New Legislative and Regulatory Framework
Recognize that OCS is used by more than 100,000 Canadians as their sole means of income in the legal adult entertainment sector.
Addition to (c) - Consider that the hatred spread online often has a disproportionate impact on women, Indigenous Peoples, members of racialized and religious minority communities and on LGBTQ2 and gender-diverse communities, persons with disabilities and people working in the adult entertainment sector;
Application
The Act should include definitions of content which is NOT harmful to ensure that legal work in the adult entertainment sector is not impacted by ideological opinions and efforts to counter exploitation or “end the sex industry”. Specific definitions to ensure that this safe, legal employment sector is not undermined by hateful expressions of myths about sex workers lives. That truth about sex work and adult entertainment, ethical research which meets the test of the Tr-Council Policy Statement (2) are only used to inform any actions taken to counter exploitation in the adult sector.
The Act should specifically state that impartiality is a critical feature of any regulation of the adult sector and that sweeping statements, based in hatred, are not entertained or allowed to influence any regulation of or enforcement against this legal employment sector.
Module 1(B): New Rules and Obligations
General Obligations – 10(a) -The Act should provide that an OCSP must take measures to ensure that the implementation and operation of the procedures, practices, rules and systems, including any automated decision making, put in place for the purpose of moderating harmful content that is communicated on its OCS and that is accessible to persons in Canada, do not result in differential treatment of any group, including adult entertainers and sex workers, based on a prohibited ground of discrimination within the meaning of the Canadian Human Rights Act and in accordance with regulations. (this addition needs to be specifically added so as to prevent misuse of rules by anti sex work zealots)
14. The Act should provide that an OCSP must generate and provide reports on a scheduled basis to the Digital Safety Commissioner on Canada-specific data about:
(f) – How they monetize harmful content – should read “how they monetize content” - harmful content assumes the OCSP is purposely monetizing harmful content and reflects an inherent bias from the onset of this proposed regulatory body.
Incident response protocol
18. [D] The Act should provide the Digital Safety Commissioner with the authority, with the approval of the Governor in Council, to establish an Incident Response Protocol for the purpose of implementing the Christchurch Call to Eliminate Terrorist and Violent Extremist Content Online and reducing the online communication of content relating to terrorist activities. The Incident Response Protocol would respond to an act or omission as described in the definition of “terrorist content” tied to an emergent, ongoing, or recently concluded real-world attack in Canada, or outside of Canada when content is shared on one or more Canadian-based OCSs.
Sex workers and adult entertainers would like to point out that the attacks in Toronto and Atlanta against massage parlor workers would qualify under this provision. This would require the removal of hateful/ untrue/ malicious content by anti sex work organizations and which has lead directly real world acts of violence and terror against the Canadian sex working community.
Content created by those groups actively promoting hatred of sex workers is wide spread and widely available in Canada and after an attack like the Toronto attack, we would hope to see those OCSP who host this kind of hateful content held to account and that content removed.
We would also hope to see any funding of these individuals and organizations via public money stopped in respect of the inherent threat they pose to the sex working community in Canada.
Module 1(C): Establishment of the new regulators
Digital Safety Commissioner
Establishment and Function
35. The Act should provide for the establishment of the Digital Safety Commissioner, whose functions are to:
(a) Oversee and improve online content moderation, by:
1. Administering and enforcing obligations;
Ensuring balanced and unbiased consideration of complaints about the legal adult entertainment sector and which reflects an understanding of the negative impacts actions taken may have on the lives and safety of Canadians working in adult entertainment and their families.
2. Engaging with and considering the particular needs of and barriers faced by groups disproportionately affected by harmful online content such as women and girls, Indigenous Peoples, members of racialized communities and religious minorities and of LGBTQ2 and gender-diverse communities, persons with disabilities and people working in sex work or the adult entertainment sector; and
2. Supporting platforms in reducing harmful content affecting peoples in Canada.
Composition
38. The Act should provide that a person appointed as Commissioner or Deputy Commissioner must declare any conflict of interest, in particular any history of a private interest in the abolition of the sex industry, and must not be a shareholder of an OCS or OCSP.
