Disinformation has been used as a tool to weaponise mass influence and disseminate propaganda. It has brought extreme fallout for economies, politics and societies around the globe. No country is immune from these online and offline harms.

We welcome the UK government’s efforts to more effectively and proactively respond to disinformation and the harms it creates. The government's consultation on its “Online Harms White Paper” provides an open and transparent foundation for having this discussion.

The GDI believes strongly that platforms and governments must put forward thoughtful and effective policy responses to disinformation and the harms created. As an organisation, we argue that to combat disinformation, we must look at the motivations of and channels for disinformation that occur across a range of platforms. Otherwise, any policy intervention by any single actor will inevitably continue to fall short.

The following recommendations are crafted in this spirit:

Define and frame disinformation more specifically as a clear source of online harms. For the GDI, to remedy disinformation, one has to look more specifically at the actions behind it: the verb - to disinform. We define ‘to disinform’ as: to purposely and/or maliciously mislead by spreading inaccurate information (in terms of the content itself and the context). The UK government's whitepaper does make a basic distinction between disinformation and misinformation. However, disinformation should not just be about the content but the context in which it is presented - and the narratives, networks and actors behind it.

Define the range of harms arising from disinformation. The harms identified in the UK government's white paper should be re-conceptualised instead as ‘harmful activities,’ and a typology of harms should be established. For the GDI, this should be based on the substance of the harm inflicted, such as:

• Increased social polarization
• Fraudulent/faulty basis for decision-making
• Erosion of trust in institutions
• Reputational harms to persons or groups
• Harassment
• Psychological distress
• Threats to personal safety

Understand and regulate the process of disinforming. The GDI believes that the best way to combat disinformation is to address the actions, incentives, actors and activities that allow disinformation to spread - rather than the specific content. Such an approach would ensure that the UK regulator does not become involved in content moderation disputes. The process of disinforming is facilitated by many actors that do not host or produce disinformation themselves.

Adopt a cross-platform approach. The GDI fully believes that the UK regulator should recognise and remedy the cross-platform process of producing harmful content. From our network mapping of disinformation actors (e.g.. those promoting the QAnon and anti-5G narratives), harmful actors often disperse their activity across a range of platforms - using different services to recruit, organise, monetise, and harm others. Mitigating harm on one platform will often require that the regulator takes a broader view of the extent to which that harmful activity moves between services.

We have submitted these recommendations as part of a broader list of asks to the UK government's consultation. If we are going to successfully stop disinformation and the harms it creates, we believe that we must view the problem as a cross-platform phenomenon that goes beyond specific content. For us, disinformation is not just a thing, but more perniciously a process.

We welcome a continued dialogue with the UK and other governments on why these recommendations are merited and how we can work together to support their achievement.