Dear Department of Internal Affairs,

I just had a two questions about the definition of 'child sexual abuse images' that is present in the March 2013 Digital Child Exploitation Filtering System Code of Practice.

First: the test that the DIA uses to determine whether an image falls within the filter is if it 'promotes or supports, or tends to promote or support the exploitation of children, or young persons, or both, for sexual purposes'. This is the same test that is used by the OFLC to determine whether a publication is objectionable.

However, I am aware that the OFLC does not restrict this definition to just publications that depict children. They include publications where the actors are over 18, but appear/presented/implied to be underage in the context of the publication (such as being a babysitter). Thus I would like to ask:

* Does the DIA include in its filtering list any websites where the persons depicted in the images are over 18, but are presented/appear/implied to be underage?

Second: the definition of 'child sexual abuse images' explicitly excludes 'representation[s] of cartoon-like characters.' However, listed in the report presented to the Independent Reference Group for Dec 2012 are 32 sites that contain only 'CGI or Hentai.' Given that hentai tends to be represented in comic form I would like to request:

* Any guidelines, criteria, or other such policies that are used to determine whether an image is a 'representation of a cartoon-like character.'

Feel free to contact me if you wish me to clarify my request.

Yours faithfully,

Joshua Grainger