We are disappointed that the following statement – submitted for the Guidance on Rights-based Law Reform to Address Tech Facilitated Gender Based Violence (TFGBV) – was not included. A lack of endorsement from partners within the Expert Group drafting and reviewing the paper, proves our point. Sex workers face disproportionate harms in the TFGBV space, and a lack of support from organisations with the power to shed light on these harms is one of the many ways vulnerable people in the sex industry are ignored. The prioritisation of institutional positions over improving the safety of sex workers is just another example of how little support there is for this group. By isolating and separating sex worker harms from that of the non sex-working population, we create a two-tiered system of justice and advocacy for those experiencing tech-facilitated abuse. We will continue to shed light on the unique, multi-source harms that this population face.
“Scotland for Decrim welcomes the recognition of tech-facilitated gender-based violence (TFGBV) as a rapidly evolving human rights issue, especially among marginalised populations such as sex workers, who are more likely to experience TFGBV. Sex workers experience a wide variety of technological harms including hacking, stalking, doxxing, impersonation, malicious reporting, coordinated harassment and various forms of image-based abuse, making them a particularly at-risk group in this area. These harms are further compounded in certain locations, whereby reporting victimisation is influenced by the partial or full criminalisation of sex work, which makes survivors fearful of seeking support or justice. Technology and digital services are essential routes for sex workers to access screening tools in order to avoid harmful clients, to obtain harm reduction information and resources and to seek out peer support in an otherwise isolated space.
Responses to TFGBV must recognise that sex workers are entitled to the same protections as any other group. They require improved access to privacy, platform accountability, and reporting mechanisms without fear of additional surveillance, deplatforming, or criminalisation as a result. As a group, we call upon tech companies and digital service providers to take a rights-based approach to this population’s intersectional harms.
Sex workers face threats from three directions: income disruption by the public driven by stigma and bias3, digital and tech companies that incorrectly moderate content and overreach beyond OSA and Ofcom guidance and perpetrators of TFGBV themselves. Tech-facilitated abuse towards sex workers should not be considered an occupational hazard by the police, tech companies or policymakers, and should instead be treated with equal gravity as abuse experienced by people who are not sex workers. Reports made by sex workers must be investigated and acted upon swiftly and without bias, with their rights and safety given primary priority.”
Sources
1. Sanders, T., Trueman, G., Worthington, K. and Keighley, R., 2023. Non-consensual sharing of images: Commercial content creators, sexual content creation platforms and the lack of protection, New Media & Society, 27 (1).
2. Understanding Technology-Facilitated Gender-Based Violence in Asia. UNFPA Asia and the Pacific Regional Office, 2024.
3. Redman and Waring, Visual Violence: Sex Workers’ Experiences of Image-Based Abuses (National Ugly Mugs, 2022).
4. Struyf P. To Report or Not to Report? A Systematic Review of Sex Workers’ Willingness to Report Violence and Victimization to Police. Trauma Violence Abuse. 2023 Dec;24(5):3065-3077. doi: 10.1177/15248380221122819. Epub 2022 Sep 26. PMID: 36154751.
5. European Sex Workers’ Rights Alliance, Sex Workers Belong on Social Media: Recommendations for Platform Accountability (2025), p. 17 and 55–56.
6. ESWA, ‘An Open Letter to the European Parliament: Addressing the Needs of Survivors of Digitally Facilitated Gender-Based Violence’ (2023).
7. Ofcom Content moderation in user-to-user online services – an overview of processes and challenges (2023)