Responses
Explore our responses to consultations, calls for evidence and other important steps towards policy or legislative change.
Parent Zone research, reports and policy responses are developed and funded directly by Parent Zone and are entirely independent of any other projects.
If you have any questions about our responses, or would like to discuss them further please email policy@parentzone.org.uk
Screen Time: Impacts on Education and Wellbeing
October 2023
This call for evidence was requested by the Department for Education (DfE) and asked for responses on how screen time can support and impact children's development, wellbeing and educational outcomes. Our response can also be found published as written evidence on the Education Committee's website.
Parent Zone believes that while screen use can provide great opportunities for students, there needs to be a balance. Our response highlighted the following points:
- Schools are well placed to model balanced screen time, by protecting screen-free learning, particularly in subjects such as Physical Education, Drama and Music.
- Teaching digital wellbeing can provide students and parents with the knowledge to make healthy decisions around screen time usage.
We gave two key recommendations for the DfE:
- Schools should receive guidance on how much time should be spent on screens throughout the school day.
- Parents should be informed of how much time their child has spent on screens during a school day and what those screens have been used for.
Call for Evidence: Gambling Regulation (July 2023)
July 2023
The DCMS committee asked for input on the Gambling Act white paper, published in April 2023. This sets out the reform of the Gambling Act 2005 and the regulation of gambling in the UK, and Parent Zone responded to the call for evidence. Our response can also be found published in the written evidence section on the DCMS Committee inquiry webpage.
Our response covered the following points:
- Parent Zone welcomes the introduction of a statutory levy.
- The gaming industry, and gambling like behaviours carried out within it, was completely overlooked within the proposals.
- Not recognising that children are taking part in non-traditional forms of gambling such as loot boxes, is a barrier to delivering the aims of the white paper.
RSHE Response as Submitted to Government
June 2023
The Department for Education announced it would be conducting a review of the statutory guidance for relationship, sex and health education (RSHE) which came into force in 2020. We were invited to provide written suggestions for the independent panel conducting the review.
Our response focused on the crucial need to centre parental engagement in the provision of PSHE education, ensuring they are well informed and supportive of the teaching.
We have specific suggestions of how the existing regulation could be changed to improve parental engagement and shared evidence which demonstrates the link between parental support for children's education and their attainment.
Ofcom Call for Evidence: Second Phase of Online Safety Regulation
March 2023
Parent Zone responded to the Ofcom call for evidence, which focused on children accessing harmful content. Our response covered the following points:
- Services should assume that children will go anywhere and access spaces that are not specifically designed for them.
- There is much evidence relating the the presence of content that is harmful to children, including on gaming platforms.
- The importance of simplicity of language when creating terms of service.
Call for Evidence: Gambling Reform
February 2023
The DCMS committee set out their intention to example the regulation of gambling and the government's process in responding to MP's concerns, and Parent Zone responded to the call for evidence. Our response can also be found published in the written evidence section on the DCMS Committee inquiry webpage.
In our response, we highlighted the following points:
- The exposure of children to gambling-like behaviours through gaming and the risks the failure to consider these behaviours poses to children.
- That it is essential for a regulator to maintain up-to-date knowledge of technological developments in their sphere, in this case – gambling and gaming.
In light of these arguments, we recommend the need for gaming to be regulated in its own right, either through the existing Gaming Commission, or the establishment of a separate gaming regulator.
Online Safety Bill (re-committed Clauses and Schedules) Call to Evidence
December 2022
This call for evidence was requested by the Online Safety Bill (re-committed Clauses and Schedules) Committee and was designed to address matters contained within the re-committed Clauses and Schedules of the bill. Our response can also be found published as written evidence on the Online Safety Bill website.
- Parent Zone supports clause 69 of the bill, outlining that pornographic service providers have, “a duty to ensure that children are not normally able to encounter content that is regulated provider pornographic content in relation to the service (for example, by using age verification).” However would like the Government to commit to bringing this in within six months of the bill’s passing.
- Parent Zone would also like to offer our support to the proposed clauses 29 and 30, tabled by the SNP, and would welcome measures to empower Ofcom to publish a strategy at least every three years setting out the measures it is taking to promote media literacy among the public.
Ofcom Online Safety Bill: Call for Evidence
September 2022
Parent Zone welcomed the opportunity to respond to Ofcom’s call for evidence on the first phase of online safety regulation, as it investigated the range of approaches and techniques platforms can use to help them meet their proposed duties under the Online Safety Bill.
Our response highlights the need for:
- Platforms to enable parents to act on behalf of their children through reporting and complaints mechanisms.
- All areas of the only world to be safe for child users, not just designated ‘child-friendly’ areas.
- A consideration of the risks of virtual private networks for children.
Response to the Joint Pre-legislative Scrutiny Committee on the Draft Online Safety Bill’s Call for Evidence
September 2021
Parent Zone welcomed the opportunity to respond to the Joint pre-legislative scrutiny, appointed to consider the government's draft bill to establish a new regulatory framework to tackle harmful content online. We highlighted several factors:
- some platforms will be more tightly age-gated for children – but hardcore pornography sites will remain open to anyone.
- the ‘Duty of Care’ described does not extend to a ‘duty to take action’ when a child is known to be at risk – for example, a child posting self harm pictures or sharing naked images.
- the resources needed to provide media literacy information to parents will be made available.
- gaming has been left out of a bill that is supposed to make the UK the safest country in the world to go online.
Our response calls for a simplification of the duty of care, which would make it more responsive – especially to new harms arising from innovative functionalities.
Response to the government’s call for evidence in the Review of the Gambling Act 2005
March 2021
Parent Zone welcomed this opportunity to highlight the ways children are gambling online and being targeted with gambling-like techniques and aggressive marketing techniques – and the need for policy reform.
Our response calls for regulatory changes and support for The Gambling Commission in protecting children and young people online – especially related to the links between online gaming and gambling.
Response to the Select Committee’s Call for Evidence on the Social and Economic Impact of the 2005 Gambling Act
September 2019
Our research shows that many children and young people are left unprotected by the existing 2005 Gambling Act.
Our response includes evidence from our reports ‘Skin Gambling: Teenage Britain’s Secret Habit’, and ‘The Rip-Off Games: How the new business model of online gaming exploits children' demonstrating the widespread phenomenon of children gambling via games.
Response to the Online Harms White Paper
July 2019
In April 2019, the government published the Online Harms White Paper, outlining plans on how to make the online space safer for children and young people. The establishment of an independent internet regulator, putting in place a statutory duty of care and greater transparency are central to its plans.
In Parent Zone's full response we make recommendations on how the Online Harms White Paper can be improved to better fulfil its purpose.
Response to the Commission for Countering Extremism’s consultation and call for evidence on Extremism in England and Wales
July 2019
This call for evidence allows for consideration of how support for parents and carers can help them understand and respond to the risk of online radicalisation and extremism.
In our response, we focus on our Home Office-commissioned Resilient Families programme, which de-stigmatises and contextualises the issue of online extremism and radicalisation to help provide support for anyone who works with families.
In light of the success of this programme and in line with our evidence-based research, our primary recommendation was to encourage a digital resilience approach, while remaining parent-focused.
Response to the ICO consultation on the Age-Appropriate Design Code
May 2019
Parent Zone supports the ICO's acknowledgement that parents are best placed to help children exercise their rights, and that increased digital literacy is important in achieving this. However, technical solutions are not an alternative to ‘good enough’ at-home parenting. The code should be implemented in conjunction with focus on building children’s digital resilience.
Response to the UNCRC General Comment on children’s rights in relation to the digital environment
March 2019
The United Nations Committee on the Rights of the Child’s invited all interested parties to comment on the concept note, which indicates at the initial stages how children’s rights are to be protected in a digital environment.
While we acknowledge the tension between parental and children’s rights in a digital environment, we need to place the best interests of the child as a priority. Our three main recommendations looked at how the General Comment could support parents to help children build resilience and effectively exercise their rights.
Response to the Gambling Commission’s Consultation on the national strategy to reduce gambling harms
February 2019
This consultation allows us to highlight the harms which result from the links between gaming and gambling – in particular, skin-gambling and loot boxes.
In our response, we focus on ‘Priority Area 2: Prevention and Education’, drawing on our expertise in helping families, educators, children and frontline services with some of the issues caused or amplified by the digital age.
Legislation needs to recognise loot boxes as a form of gambling and the regulation that allows skin gambling sites to proliferate needs to be tightened.
Response to the Gambling Commission's Age Verification Consultation
November 2018
The Gambling Commission’s Age-Verification Consultation is an opportunity to highlight the increasing number of easy-access unlicensed gambling sites available to children.
In our response, we emphasised how the number of children gambling online is disproportionate to the 20% of parents that feel the need to discuss gambling with their children. Many of these children are completely unaware of the negative consequences of their actions, spiralling into issues about how they value money.
Parents often do not feel confident in talking to their children about these issues, in part because of a lack of knowledge of the link between gambling and gaming – as referenced in our report into skin gambling.
Response to the Department for Education consultation on the changes to the teaching of Sex & Relationships Education and PSHE
February 2018
The government’s consultation on updating Sex and Relationships Education guidance, published in 2000, is an opportunity to align education and legislation with children’s lived experiences, to keep them safer both on and offline.
Among the changes proposed were excluding sex education from primary education, and for parents to have a right to withdraw children from sex education at secondary level.
We have no wish to undermine the rights of parents; but the right to withdraw is not aligned with the biggest area of concern for the parents we speak to: the lack of information and confidence about talking to their own children about online risk.
Screen Time: Impacts on education and wellbeing