The Scottish Council for Voluntary Organisations (SCVO) appreciates the opportunity to respond to the UK government’s consultation ‘[Growing up in the online world](https://www.gov.uk/government/consultations/growing-up-in-the-online-world-a-national-consultation)’. SCVO is the national body in representing the voluntary sector (charities, social enterprises, and voluntary groups, aka third sector) in Scotland, with a membership of 3,000+ organisations. Our mission is to champion the sector’s social and economic contributions, provide essential services and debate big issues. The sector in all its diversity is a powerful force for positive change across Scotland and a significant part of our economy, with over 46,500 voluntary organisations and over 800,000 volunteers. For further information please refer to SCVO's State of the Sector 2025. This consultation touches on issues that are central to how we promote and support digital inclusion. SCVO has been leading the delivery of digital inclusion across Scotland for 15 years and continues to do so through a range of different programmes. In preparation of our response we have engaged with organisations working with children and young people, with a particular focus on smaller organistions that may otherwise struggle to resource the time to respond to this consultation. Our response is therefore shaped by the views of childcare practitioners, youth parliament members, charity board members, digital safety experts, and third-sector organisations.  Our response has focused on 5 areas that are most relevant to our work on digital inclusion.  ### Organisations and voices represented The following organisations and individuals contributed evidence to this consultation. Their thoughts are cited throughout this report, and they are referred to collectively as ‘stakeholders’: * [Seamab](https://seamab.org.uk/) * [Kids n Clicks](https://kidsnclicks.com/) * [Y Sort It](https://ysortit.com/) * [Scouts Scotland](https://scouts.scot/) * [Member of the Scottish Youth Parliament (MSYP)](https://syp.org.uk/) * [Cake or Dice](https://cakeordice.co.uk/) * [Strange Town](https://strangetown.org.uk/) * [Sewing Together All Nations](https://www.sewing2getherallnations.com/) * National organisation working on behalf of children and young people The consensus amongst stakeholders is that outright age-based bans are a 'false promise'. The evidence points instead towards Safety by Design, mandatory corporate accountability, sustained third-sector funding, and a public health approach to online wellbeing that treats digital harm on a par with smoking or road safety, alongside adult role modelling. You can read our [consultation response here](https://files.scvo.scot/2026/05/Growing-up-in-the-online-world-SCVO-response.pdf). Conclusions and recommendations ------------------------------- The insights gathered from our engagement forms the basis of a set of clear and consistent conclusions. Together, they point towards a fundamental reorientation of how the UK Government approaches online safety for children and young people away from symbolic prohibitions and towards structural, systemic, and adequately resourced reform. ### 1.  The inefficacy of outright bans There is profound consensus that age-based bans specifically for the under-16 group are practically unworkable and potentially counterproductive. Technical workarounds render them easily circumventable, and they risk creating a 'forbidden fruit' effect that leaves children less equipped for eventual unrestricted access. Any minimum age threshold must be accompanied by robust, privacy-respecting verification technology enforced at the platform level not left to self-regulation by commercial entities. ### 2.  Safety by design as a mandatory standard The most resonant recommendation across our engagement is the introduction of ‘safety by design’ as a legally enforceable standard. Platforms accessible to under-18s should be required to apply age-appropriate protections automatically eliminating addictive features, algorithmic amplification of harmful content, and opaque privacy settings. Just as toys must meet safety standards before reaching the market, digital platforms should be subject to equivalent regulation. ### 3.  A public health framework for online harm The evidence strongly supports treating online harm as a public health issue, requiring a comparable policy response to campaigns for road safety, anti-smoking, or anti-obesity. This means sustained, population-level communication campaigns; integration of digital wellbeing into primary care settings; and a recognition that the goal is healthy integration with technology, not prohibition. This needs to recognise that the ‘problem’ sits within telecommunications, a UK Government reserved function, but part of the solution is located within health, which is a devolved competency. Collaboration and coordination between UK Government and Scottish Government is necessary to facilitate this response. ### 4.  Sustainable funding for the voluntary and community sector Youth organisations and charities cannot be expected to fill the safety gap left by platforms and schools without sustainable funding. Short-term grants are insufficient. Any funding or resource allocated to Scotland, either directly or through Scottish Government, should be compatible with Fair Funding principles e.g., multi-year funding and inflationary uplifts. ### 5.  Addressing the adult digital crisis Our engagement reveals that online harm is a societal issue affecting adults as well as children. Parents who are struggling with their own 'doomscrolling' and digital addiction are less well-equipped to model or enforce healthy digital habits. Support must extend beyond children to encompass the adults in their lives through community training, accessible guidance, and a cultural shift that destigmatises adults seeking help with their own digital wellbeing. For further information please contact: **Darran Gillan, Digital Inclusion Development Officer** [Darran.Gillan@scvo.scot](mailto:Darran.Gillan@scvo.scot) --- ## About SCVO SCVO (Scottish Council for Voluntary Organisations) is the national membership organisation for Scotland's voluntary sector. Our role is to champion the role of voluntary organisations in Scotland and to support them to do work that has a positive impact. SCVO supports members and the wider voluntary sector with all aspects of setting up and running a voluntary organisation. SCVO represents the needs and concerns of the voluntary sector to the Scottish government in Holyrood and UK government and Westminster. Through our learning and events programme SCVO offers training and development opportunities to the sector. Members access an extensive membership benefits package including specialist, in-depth, 1-to-1 guidance from our Information Services team and from professional service partners. Access to exclusive membership networks (including comms, employers, governance and policy) supports members to grow their connections, stay up to date, exchange ideas and views with peers, and learn through tailored, learning opportunities. SCVO members enjoy free access to Funding Scotland Premium to stay on top of funding opportunities to support their organisation’s financial resilience. Discounts and savings savings on SCVO products and services (including our HR service, managed IT support, payroll service and events and training) and partner offers provide members with support to allow them to focus on delivering their organisation’s goals. Further SCVO products and services include [extensive digital support](https://scvo.scot/support/digital), a climate action resource [Growing Climate Confidence](https://climateconfident.scot), a voluntary sector publication [Third Force News](https://tfn.scot) and a voluntary sector jobs and recruitment service [Goodmoves](https://goodmoves.org). For more information on SCVO membership, visit [SCVO membership](https://scvo.scot/membership)