By Valarie Waswa
On June 13, 2025, KICTANet joined a high-level consultative meeting organized by Watoto Watch Network. The session brought together representatives from various civil society organizations including Amnesty International Kenya, the Association of Media Women in Kenya (AMWIK), Internews, and Kwa Wote Initiative. The purpose of the gathering was to review and offer feedback on the Draft Industry Guidelines for Child Online Protection and Safety in Kenya.
Context: International Day of the African Child and Budget Concerns
The meeting came just days before the International Day of the African Child, marked annually on June 16. This year’s theme, “Planning and Budgeting for Children’s Rights: Progress Since 2010,” emphasized the urgent need to allocate sufficient resources for child protection. It was noted that only Ksh 126 million had been earmarked for child protection per Kenyan child in the 2025/2026 fiscal year budget, a figure many considered inadequate in light of the challenges children face online.
To kick off the session, participants engaged in light-hearted tech trivia and interactive polls. These activities helped set the tone for a collaborative discussion while reinforcing the importance of digital literacy in today’s world, especially among children.
Engaging Digital Literacy Activities
One of the key agenda items was the title of the draft guidelines: Communications Industry Guidelines for Child Online Protection and Safety in Kenya. Participants questioned whether the phrase “communications industry” might limit the scope of stakeholders expected to take responsibility. While some felt the term was too narrow, others pointed out that the guidelines were intended primarily for licensed communication service providers. A compromise was reached by recommending that the term “industry” be clearly defined within the document to ensure inclusivity while maintaining clarity.
Discussions also focused on what constitutes a genuine commitment by organizations to child online safety. Participants suggested a range of measures including the publication of internal policies, public declarations, the appointment of child safety officers, and the formation of internal oversight committees. The consensus was clear: written commitments must be backed by practical, consistent action.
Flexible Policy Review Cycles
The frequency of policy reviews also surfaced. While some favoured an annual review cycle, others proposed a longer two-year interval to allow organizations, particularly smaller enterprises, to implement changes without undue pressure. Rather than enforcing a one-size-fits-all timeline, it was recommended that organizations adopt flexible review schedules, guided by their operational capacities, but with clear accountability mechanisms.
Another major area of concern was enforcement. Questions were raised about who would monitor compliance once the guidelines are adopted. Establishing a national task force or multi-sectoral working group gained support. Such a body could track progress, offer technical assistance, and foster collaboration across sectors. Digital platforms such as X Spaces and virtual town halls were also proposed to enhance transparency and public engagement.
Importantly, the conversation emphasized the need to include children in policy discussions affecting them. Participants proposed forming a national child advisory panel that meets biannually to provide input on product design, safety strategies, and regulatory frameworks. Kenya already has several structures in place, such as county-level Child Advisory Committees and the National Children’s Assembly.
Strengthening these platforms and ensuring their integration into national policy conversations was seen as a practical next step.
Data protection for minors was another focal point. Participants questioned how much data should be collected when children access digital services and debated whether requiring birth certificates or national IDs was appropriate. The guidelines, they argued, should provide clear boundaries on what is necessary and ethical when dealing with children’s data.
Including Children’s Voices in Policy
Reporting mechanisms were also scrutinized. For child users, overly complex systems can be a barrier. The group emphasized the importance of accessible, child-friendly reporting channels. Options discussed included SMS, WhatsApp, mobile apps with visual guides, and multi-language support including braille and sign language.
Reports must be confidential, staff must be trained to handle complaints sensitively, and resolution timelines must be clearly outlined. The American “Take it Down” model, which requires platforms to act on flagged content within 48 hours, was presented as a possible benchmark.
Breakout sessions were held to allow for a deeper review of specific sections of the draft. Section 13.4, for instance, which mandates quarterly reporting on child online safety complaints, lacked performance indicators.
Recommendations included introducing KPIs, tracking the number of complaints resolved, documenting training efforts, and conducting third-party audits. It was also suggested that organizations be provided with standard templates to help them prepare and submit their child protection policies more effectively.
A Shared Responsibility for Child Online Safety
The meeting ended with a strong sense of urgency and shared responsibility. As internet access becomes more widespread, the risks facing children in digital spaces grow more complex. The group agreed that safeguarding young users is not a task for regulators alone. It demands a collaborative approach involving government agencies, civil society, the private sector, and children themselves.
The conversation sparked innovative ideas and actionable recommendations, many of which are expected to be reflected in the final version of the guidelines. With continued cooperation and follow-through, the safety of children online in Kenya can move from aspiration to reality.
Valarie Waswa is a Legal Fellow and Gender Digital Rights Advocate at KICTANet