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LGBT Tech Files Comments with the National Telecommunications and Information Administration (NTIA)

On November 16, LGBT Tech submitted comments to the National Telecommunications and Information Administration (NTIA) in response to the Kids Online Health and Safety Request for Comment.

There are more than 5.7 million LGBTQ+ youth in the United States, with both a unique reliance on online access and a distinct set of risks as a result. While only 40% of LGBTQ+ young people report that their homes are affirming, 68% say that online spaces are. These teenagers are more likely than their peers to use these platforms and far more likely to be honest about themselves while on them. Conversely, LGBTQ+ Americans report the highest rates on online harassment among marginalized populations, and transgender Americans experience the most harassment of any demographic category. While access to online spaces is irreplaceable for LGBTQ+ youth, making that access as safe as possible is crucial work for industry and government alike.

LGBT Tech’s comments to NTIA include the following recommendations for online platforms working to strike a balance between youth safety and autonomy:

  1. Guidelines and Reporting: Clear policies and explicit community guidelines emphasizing the protection of marginalized communities; transparent reporting mechanisms allowing users to report abusive content and behavior.

  2. Harm Detection: Machine learning and AI mechanisms for automated harm detection, trained to prevent injurious content while avoiding false positives; involvement of human moderators to provide nuance and prevent undesirable outcomes.

  3. User-Centric Features: Enhanced and customizable tools for muting, blocking, and filtering content; creation of youth-specific features and areas, such as private groups and moderated forums, ensuring age-appropriate interactions.

  4. External Partnerships: Collaboration with NGOs, academic institutions, and organizations to understand and counter evolving harassment tactics targeting marginalized users.

LGBT Tech also recognizes the government's role in finding this balance, particularly when it comes to data privacy. Collection of user activity data poses significant privacy risks for LGBTQ+ youth, and consumer privacy and data security measures are imperative to prevent improper disclosure or compromise of LGBTQ+ user data.

Finally, the comments advise caution regarding certain governmental efforts that may, even unintentionally, inadvertently jeopardize LGBTQ+ youth privacy. Overbearing content moderation policies, parental control requirements, and legislation lacking age-specific considerations could hinder online autonomy and community access.

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