eco Complaints Office

Combatting Illegal Internet Content and Dedication to Youth Media Protection

Since 1996, we at the eco Complaints Office have been fighting successfully against illegal content on the Internet and are committed to ensuring that illegal content is taken down and criminal offences are reported to the authorities. In fulfilling this commitment, cooperation with the various stakeholders and neutral and transparent processes are of equal importance.

Our work is based on voluntary cooperation with society as a whole, and its fundament is that of self-regulation of providers and the engagement of Internet users. From the outset, eco has cooperated with law enforcement agencies in the fight against child sexual abuse material and other illegal Internet content.

We are also the contact partner for eco members, the state, society and politics.

Internet users can report suspected illegal Internet content to the eco Complaints Office, free of charge and anonymously: for example, under international.eco.de/eco-complaints-office. The Complaints Office’s lawyers then assess whether the reported content violates German law and take appropriate measures if necessary.

The eco Complaints Office can also be reached via the portal https://www.internet-beschwerdestelle.de/en, which it operates together with the German Association for Voluntary Self-Regulation of Digital Media service providers (FSM), as well as via the German information platform for young people at juuuport.de/melden.

Statistics

In 2023, a total of 65,998 complaints reported on potentially criminal content or violations of the youth media protection provisions. Around a quarter of these reports were “actionable” complaints.

Compared to the previous year, the number of actionable complaints almost doubled: With 17,493 cases, in 2023 the eco Complaints Office consequently recorded a new peak in actionable complaints.

The actionable complaints were forwarded – depending on the type of violation and server location – to law enforcement agencies, content providers, host or platform providers and/or members of the INHOPE network.

In terms of content, the majority of complaints concerned depictions of the sexual abuse and sexual exploitation of minors, defined as Child Pornography in Section 184b of the German Criminal Code. The proportion of anti-constitutional content was again strikingly low, comprising 0.26 per cent of all actionable complaints.

The take-down times for depictions of sexual abuse of children in Germany occurred more quickly in 2023 compared to the previous year: Websites with Child Pornography hosted in Germany were offline (“taken down”) within 1.86 days on average, whereas globally it took 6.17 days.

A total of 98.35 per cent of the illegal Internet content reported upon by the eco Complaints Office –such as depictions of sexual abuse, incitement of the masses, and depictions of violence – were removed worldwide. This demonstrates once again that self-regulation works – also internationally.

Network and committee work/political engagement in 2023: an excerpt

INHOPE (International Association of Internet Hotlines)

INHOPE is the international umbrella organisation of Internet hotlines that handle complaints concerning depictions of the sexual abuse of minors. Founded in 1999, by eco among others, it has grown to encompass 54 hotlines in 50 countries.

In 2023, INHOPE continued to promote the exchange of experience between hotlines by providing financial assistance for work shadowing at partner hotlines. The eco Complaints Office also benefited from this: both as a host for colleagues from Portugal, Poland, Finland and Hungary, and as a visitor at the French hotline. In addition, an “Advanced Analyst Workshop” was held, in which the eco Complaints Office also participated. Furthermore, the eco Complaints Office actively contributed the association’s expertise on the topic of end-to-end encryption to discussions at the INHOPE level.

From June 2018 to December 2023, Peter-Paul Urlaub, Consultant at the eco Complaints Office, was a member of the INHOPE Executive Board and held the role of Treasurer from July 2020.

Cooperation on youth media protection with other relevant actors

In addition, the eco Complaints Office was in contact with other relevant actors in the field of youth media protection. The following activities can be highlighted in this regard:

In proceeding to build on the work of previous years, collaboration with supervisory bodies and self-regulatory organisations on common and specific topics was continued. Examples included the participation of representatives of the State Media Authority of North Rhine-Westphalia (LfM) in the event organised by the eco Complaints Office for Safer Internet Day 2023, as well as the work of eco Complaints Office employees as youth protection experts for USK online. The Complaints Office also cooperated with the LfM as part of the initiative “Prosecute, don’t just delete”.

The German Federal Agency for the Protection of Minors in the Media (BzKJ) is another important contact partner with regard to the assurance and further development of youth media protection. In 2023, representatives of the eco Complaints Office took part in several events organised by the BzKJ as part of the “Future Workshop”, addressing topics on “Sexual Violence and Harassment in the Digital Sphere”, “Endangering the Capacity for Democracy”, and “Loss of Control in the Digital Sphere”. Furthermore, for many years now, employees of the eco Complaints Office have been appointed as assessors of the review body and contribute to the indexing decisions of the BzKJ.

In 2023, “trusted flagging/reporting” was also an essential element of the eco Complaints Office’s effective work. The special reporting channels for trustworthy whistleblowers enable direct interaction between hotlines and providers, which simultaneously has a positive effect on reaction times.

Law enforcement agencies

Law enforcement is an important element in combatting illegal Internet content. The eco Complaints Office works within the framework of complaint processing to ensure that illegal content is taken down and that criminal offences are reported. Beyond complaint processing, the Complaints Office also cooperates with law enforcement agencies at both the federal and state levels.

In the fight against depictions of the sexual abuse of children, close and effective cooperation with the German Federal Criminal Police Office (BKA) takes place, with this also reflected in the German federal government’s report on the success of deleting Child Pornographic web content. The most recent report, published in June 2023, once again showed that the principle of “take-down instead of blocking” and the cooperation of the hotlines, the BKA and the Federal Agency for the Protection of Children and Young People in the Media (BzKJ) present very effective means for combatting illegal Internet content. The German federal government has published its 2023 Annual Report on the deletion of child pornography web content.

In the area of state protection offences, the eco Complaints Office cooperates with police authorities and public prosecutor offices at both the federal and state levels. Since 2019, eco has also been a member of the North Rhine-Westphalian initiative “Prosecute, don’t just delete”, and thereby actively supports the rigorous criminal prosecution of hate speech on the Internet.

In addition, the collaborative work between the Complaints Office and the police at state level is part of a cooperation agreement between eco, Networker NRW and the North Rhine-Westphalia Criminal Police Office (LKA NRW).

Support for regulatory issues

From a regulatory perspective, the European Commission’s proposal for a “Regulation on laying down rules to prevent and combat child sexual abuse” (CSAM Regulation) was the eco Complaints Office’s primary topic in 2023. Due to the “affectedness” on the member companies and established hotlines, this European planned legislation is therefore of particular significance for eco as a stakeholder and as a hotline operator. The eco Complaints Office also addressed the amendment of the German Interstate Treaty on the Protection of Minors in the Media (JMStV) and the key points of the Federal Ministry of Justice for a law against digital violence.

Details on these legislative proposals can be found in “Policy, Law & Regulations / Political Representation”.

Annual Report of the eco Complaints Office

Transparency is essential for the work of a hotline. With this being the case, in March 2023 we launched the seventh independent Annual Report of the eco Complaints Office, with the participation of MP Catarina dos Santos-Wintz as the keynote speaker at a political breakfast held in the eco offices in Berlin.

Youth Media Protection Expert Lunch & eco Youth Protection Officer Service

The portfolio of the eco Complaints Office is rounded off by individual services in the field of youth media protection that are offered independently of the general complaints work. As such, when it comes to assessing online offers and necessary measures, members can benefit both from the Complaints Office’s fully legally qualified personnel and its circa 25 years of expertise in the field of youth media protection.

Youth Media Protection Expert Lunch

With the “Youth Media Protection Expert Lunch”, the eco Complaints Office offers an open forum targeted exclusively at association members who are active in the field of youth media protection, with the aim of enabling the exchange of experiences and sharing information.

Two to three planned meetings are held per year, with additional relevant parties and external experts sometimes also invited to contribute.

eco Youth Protection Officer Service

The roles and functions of the youth protection officers are:

• Advising the provider
• Contact person for users
• Point of contact for official oversight

Youth protection on the Internet is a task for society as a whole. With the eco Youth Protection Officer Service, eco members have the opportunity to make their contribution to this cause. Certain telemedia providers with content that is developmentally impairing or youth endangering, as well as providers of search engines, may also be obliged to appoint a Youth Protection Officer in accordance with Section 7 of the German Interstate Treaty on the Protection of Minors in the Media (JMStV).

With the eco Youth Protection Officer Service, the eco Complaints Office comprehensively supports telemedia providers in the implementation of this obligation or in the voluntary appointment of a Youth Protection Officer. The service offers the following functions and benefits:

• Comprehensive consultation on matters relating to youth protection
• A neutral point of contact vis-à-vis users
• A minimisation of liability risk
• Prevention of official fines and written warnings
• An increase in user trust through effective youth protection
• Current information and updates on developments and legal changes in the area of youth media protection

Further information on the working approach, statistics and services of the eco Complaints Office is available at: international.eco.de/eco-complaints-office, as well as in the eco Complaints Office Annual Report 2023.