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Contribution to the Directive on Combating the Sexual Abuse of Children

ASSEDEL has carefully examined the “Proposal for a Directive of the European Parliament and of the Council on combating the sexual abuse and sexual exploitation of children and child sexual abuse material”. The objective of this proposed directive is to enhance the effectiveness of the fight against child sexual abuse by replacing the previous directive.

The proposed directive focuses on strengthening prevention of abuse, prosecution of perpetrators and support for victims. It does so by taking into consideration new technological challenges that have arisen in recent years such as Artificial Intelligence and perpetrators’ increased possibilities to hide their identity. ASSEDEL welcomes the revised directive and considers the additional articles addressing cross-border cooperation and new online challenges as improvements. While we recognize the directive’s significant advancements, we have identified areas where further refinement could enhance its precision, comprehensiveness, and inclusivity.

For instance, ASSEDEL noted that certain articles could benefit from greater clarity to prevent potential misinterpretations. Additionally, we observed that the directive does not address pedophilic disorder or its treatment, a critical aspect in the context of child sexual abuse prevention. Furthermore, we raised concerns regarding the protection of citizens’ data as well as financial implications of implementing intervention programs and measures.

While evaluating the directive, we have taken into consideration the protection of human rights and fundamental freedoms to ensure that our suggestions are in line with the core values of our organization. Since children are an especially vulnerable group, their protection from sexual abuse is of major importance in the struggle for human rights.

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