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Date Published
June 04, 2021

Intimate image abuse against women and girls, and other forms of online VAWG, is part of the continuum of violence and abuse that occurs offline. It takes place in the context of gendered norms of popular culture that can reinforce harmful stereotypes and gender inequality. We also know, as our report with online abuse charity Glitch The Ripple Effect: Online abuse during COVID-19 highlights, that online abuse of women and girls is compounded by multiple intersecting inequalities such as racism, homophobia and ableism. 

The Law Commission recently consulted on intimate image abuse and EVAW and the Faith and VAWG Coalition submitted a joint response on what is needed to ensure intimate image abuse against all women is properly addressed.

Read our submission in full here: FINAL EVAW and Faith and VAWG Coalition Intimate Image Abuse Consultation response May 2021

In our joint submission, we made the following recommendations:

On the definition of “intimate image”

There should be a comprehensive definition of “intimate image” which ensures all women, particularly those otherwise minoritised and marginalised, have the ability to control the boundaries of their intimate lives, and have a right to ‘intimate privacy’. This would include:

    • Images of women that would be intimate according to their religious or cultural expectations. This should go beyond ‘religious attire’ but must account for contexts and environments that would make an image ‘intimate’. Any changes to the law must only come after consultation with the specialist Black and minoritised- led ‘by and for’ VAWG sector,
    • Sexual images,
    • Nude/semi-nude images,
    • Altered/deepfake images.

On intimate image abuse offences

There should be a straightforward single offence – This would ensure that all intimate image abuse (including upskirting and downblousing) are covered by one offence to strengthen understanding and clarity.

There should be no more ‘serious’ additional offence related to motivation of perpetrator as this does not accurately reflect the overlapping, shifting motivations of intimate image abuse perpetrators and would be inconsistent with most criminal law offences.

On support for all those reporting any form of intimate image abuse

Automatic anonymity should be given for all those reporting any form of intimate image abuse and further measures to protect complainants during any trial process, along with further measures to protect complainants during any trial process.

Additionally, any legal change must be accompanied by a commitment to increase and prioritise sustainable funding for specialist VAWG organisations to help victims and survivors get images and videos taken down and to provide long-term and specialist support, with particular emphasis on ‘by and for’ Black and minoritised women’s VAWG organisations.

On regulation of social media and porn companies

There should be the establishment of a regulator with powers to order social media and porn companies to take down images, as well as supporting and funding educational and preventative initiatives.

On a public health approach to online VAWG

There must be a holistic, public health approach to online VAWG, including providing clear recommendations to employers on how to help ensure their employees are safe online, and publishing national guidance on digital safety. There must also be a recognition of online VAWG in the forthcoming Online Safety Bill.


With the recently published draft Online Safety Bill currently falling short of what is needed to protect and support all victims and survivors of online abuse, we are calling on the Government to take this unique opportunity to tackle all forms of online VAWG, including intimate image-based abuse, that many women and girls face on a daily basis.

Date Published
June 04, 2021
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