Good afternoon, committee members. It is an honour for me to appear before you today.
Daughter Project Canada is a Canadian non-profit organization working to end the sexual exploitation of children and youth through awareness, prevention and advocacy.
As a national organization, our work is informed by direct engagement with communities across Canada and by the growing realities of online harm facing Canadian children. Daughter Project's publicly available resources, including the sextortion safety guide, were developed in response to a demonstrated need from Canadian families.
Daughter Project Canada supports the intent of Bill C-16. We welcome recognition of harms such as coercive control, online sexual exploitation and technology-facilitated abuse, particularly as they affect children and youth.
It is our view that any Canadian child accessing the Internet can quickly become at risk. With this in mind, Daughter Project has made two recommendations for amendments to Bill C-16 and two recommendations around implementation if it is passed.
First, strengthen the definition of intimate image to reflect a harm reduction standard. We recommend that the definition of intimate image in Bill C-16 be amended to replace the current standard, “likely to be mistaken for a visual recording of that person”, with “that is presented or capable of being presented as a visual recording of that person.” We submit that the harm of a sexualized deepfake or a non-consensual intimate image does not depend on how convincing it is. The harm lies in its creation and potential distribution and its impact on the dignity and well-being of the person depicted.
Second, address online exploitation through not only criminal penalties but also shared responsibility. Children are being exploited online in environments designed for engagement and addiction, not safety. Effective prevention requires shared responsibility among individuals, platforms, communities and governments. Individual accountability is essential, but systems shape risk. Criminalizing conduct after images are created or shared does not stop initial harm. Therefore, rapid takedown mechanisms, platform accountability and digital literacy education are essential complements to the law. If the bill is passed, we recommend that criminal offences are paired with mandatory national prevention.
Our mandate focuses on preventing exploitation before a child is harmed. Our concern is with ensuring that laws do not unintentionally place victims, especially young people, in greater danger or discourage disclosure of abuse. Children and youth who experience exploitation often require years of trauma-informed counselling and supports such as stable housing and family connections. Without sustained investment, we risk seeing survivors cycle back into vulnerability even after their abusers have been convicted. Root causes such as harmful gender norms, online normalization of sexual exploitation, lack of digital safety education and economic vulnerability are not addressed through criminal offences alone. Addressing these requires prevention strategies alongside legislation.
Lastly, mandate national data collection and public reporting on child sexual exploitation. Daughter Project Canada recommends the introduction of statutory obligations to collect standardized national data on child sexual exploitation and technology-facilitated abuse, and to publicly report on trends, prosecution outcomes and prevention gaps.
Bill C-16 defines and criminalizes new forms of exploitation, but it does not require systematic data collection or reporting. Other organizations appearing before this committee have highlighted that a lack of data undermines both prevention efforts and accountability.
In closing, Canada cannot arrest its way out of child exploitation. If Parliament recognizes new harms, it must also invest in stopping those harms before a child becomes a victim. Prevention reduces victimization upstream of the judicial system. Education for parents, caregivers, educators and communities, especially around online grooming and coercive behaviour, is one of the most effective ways to reduce demand for criminal justice intervention.
Thank you, Chair and committee members, for your commitment to the safety of Canadian children and youth represented in this bill.