How Carnegie’s Blood Money Bought British Law: The Online Safety Act Exposed

red padlock on black computer keyboard
Photo by FlyD on Unsplash

The UK’s Online Safety Act was sold as child protection. In reality it is a closed‑door policy experiment, drafted by a small network around Carnegie UK and Lorna Woods, that ignored the technical, legal, and social realities of the modern internet.

Sign the Repeal the Online Safety Act

petition.parliament.uk/petitions/722903

https://www.youtube-nocookie.com/embed/lJ2AokZujC0?rel=0&autoplay=0&showinfo=0&enablejsapi=0

Part 1: Meet Andrew Carnegie, Industrial Terrorist

Black and white portrait of a man with a beard and mustache, wearing a suit and bow tie, looking directly at the camera.

Andrew Carnegie was not a kind businessman. He was one of America’s most violent industrialists who used private armies to attack his own workers.

The Homestead Massacre 1892

Carnegie hired 300 armed Pinkerton agents to attack striking steel workers in Pennsylvania (PBS American Experience, 2017). The battle lasted 13 hours. Ten people died. Dozens were wounded (Wikipedia, 2003).

A historic illustration depicting a large crowd outside a building with the sign 'EINTRACHT SÄNGER HALLE.' The people are raising their arms, some holding sticks, indicating a protest or rally atmosphere.

Carnegie built a fortress around his steel mill with 12 foot high barbed wire fences. Workers called it “Fort Frick” (Digital Public Library of America, 2016). This was not defence. This was preparation for war against American workers.

A historic illustration depicting a confrontation between a group of striking workers and law enforcement, featuring individuals with raised arms, weapons, and a backdrop of industrial smokestacks.

Death Trap Factories

Carnegie’s workers died regularly from preventable accidents. From 1910 to 1913, steel workers had injury rates of 44.1 per million man hours (Metal Forming Solutions, 2019). In Pittsburgh, 20% of all male deaths came from steel factory injuries (Melbado, 2025).

Workers got almost no safety equipment. As one worker testified:

“Sometimes a chain breaks, and a ladle tips over, and the iron explodes. Sometimes the slag falls on the workmen”

(PBS American Experience, 2017).

Wage Slavery

Carnegie paid workers about $10 per week while he made $92,000 per day (Internet Public Library, 2023). Workers could barely feed their families while Carnegie built million dollar castles.

Workers laboured 12 hours per day, 7 days per week, 364 days per year. Their only holiday was July 4th (Britannica, 2025). One day of freedom in exchange for industrial slavery.

Part Two: The Philanthropy Scam

In 1901, Carnegie sold his steel company for $480 million to banker J.P. Morgan (Bill of Rights Institute, 2025). Only then did he start giving money away.

Carnegie’s “generosity” was reputation laundering. He built libraries for educated middle class people while his own workers could not afford books because they worked 84 hour weeks for starvation wages (IPL, 2023).

Bar chart depicting Carnegie UK finances from 2020 to 2024, showing annual income and expenditure in millions of pounds.

The UK Connection

In 1913, Carnegie created Carnegie UK Trust with $10 million (Wikipedia, 2009). This money came directly from profits made by killing and exploiting American workers.

Today, that blood money has grown substantially and exponentially thanks to long term yields on investments (Carnegie UK Trust, 2024).

Part Three: How Carnegie UK Captured British Internet Law

A timeline illustrating key events related to the UK Online Safety Act from 2018 to 2024, including milestones for Carnegie and Government initiatives.

Carnegie UK Trust did not just influence the Online Safety Act 2023. They wrote it. This is not interpretation. This is their own admission.

The Timeline

  • 2018: Carnegie UK begins publishing online harms proposals (Carnegie UK, 2024)
  • December 2019: Carnegie UK publishes complete “Draft Online Harm Reduction Bill” (Carnegie UK, 2024)
  • April 2019: UK Government publishes Online Harms White Paper adopting Carnegie’s “duty of care approach at its core” (Carnegie UK, 2024)
  • 2021: Carnegie UK provides evidence to multiple Parliamentary committees (Carnegie UK, 2024)
  • October 2023: Online Safety Act receives Royal Assent

Carnegie UK’s Own Admissions

Carnegie UK openly admits they controlled the process:

“We are pleased that the UK government has adopted in part our approach”

(Carnegie UK, 2024)

“Our work has influenced the recommendations of a number of bodies”

(Carnegie UK, 2019)

“Our work was repeatedly cited in debates by Parliamentarians”

(Carnegie UK, 2024)

Part Four: The Players Behind the Scenes

Professor Lorna Woods

A woman with gray hair and glasses, wearing a leopard print top, is looking thoughtfully towards the camera. In the background, there is a painting of a sheep and a desk with various papers.

Lorna Woods, heralded as the creator of the “duty of care” framework underlying the UK’s Online Safety Act, has received an OBE in 2020—a government honour supposedly recognising her services (Family Online Safety Institute, 2025).

However, a critical examination reveals that her work, entirely funded by a billionaire’s private foundation, has predominantly served to expand state surveillance and control over ordinary citizens under the guise of “internet safety.”

Her “duty of care” framework isn’t child protection it’s a Trojan horse for mass surveillance disguised as academic respectability.

Woods’ career maps a consistent belief in state‑led regulatory control dressed as public protection. She treats roles with organisations like Carnegie UK as professional prestige rather than contested political territory. The deeper context of her funders, collaborators, and the societal needs of a digital‑first world appears missing from her analysis. This is an approach rooted in outdated legal and policy thinking — applying twentieth‑century centralised governance models to twenty‑first‑century technology.

Her “duty of care” framework shows the problem. It is unworkable as technical regulation, dismissed by credible legal‑tech experts as incapable of scaling without mass surveillance infrastructure. The Online Safety Act codified that framework into law. The backlash is industry‑wide and sustained, yet the government refuses to retreat. The design flaws are now obvious, destabilising both policy credibility and sector confidence. Woods’ law has become a critical point of failure for the very elite governance system she serves.

The DRIPA Deception

When the UK government rushed through the Data Retention and Investigatory Powers Act (DRIPA) in 2014—emergency legislation that vastly expanded surveillance powers Woods was notably absent from the academic letter condemning it as a “surveillance state stitch up” (TechCrunch, 2014).

While 38 other academics signed an open letter warning that DRIPA represented “expansive and intrusive powers of the state” being extended through undemocratic processes (Paul Bernal’s Blog, 2015), Woods was working within the system to legitimise such powers.

The “Duty of Care” Deception

Woods’ signature achievement—the “duty of care” framework underlying the Online Safety Act—represents sophisticated regulatory capture disguised as child protection.

Mass Surveillance Dressed as Child Safety

The academic literature makes clear that Woods’ duty of care concept creates legal obligations that can only be fulfilled through comprehensive surveillance. As one critical analysis noted, the framework “could result in the blocking of legal, subjectively harmful content” and create “an unacceptable chilling effect on free expression, resulting in a draconian regulatory environment” (Technology and Regulation, 2019).

Woods developed this framework with Carnegie UK Trust funding, working directly with former government insiders like William Perrin.

This was commissioned policy work channelled through academic institutions to give it the appearance of independent research.

The Authoritarian Implementation

The Online Safety Act that emerged from Woods’ framework grants Ofcom unprecedented powers to:

  • Demand access to private communications
  • Require “safety by design” that can only be achieved through pre-screening all content
  • Impose criminal liability on company executives for non-compliance

Woods openly celebrates these powers.

As she stated when the Act passed:

“The Bill is significant as it marks a move from self-regulation… to regulation under which services are accountable”

(University of Essex, 2023).

This is authoritarian language. She is celebrating the end of voluntary compliance and the beginning of state forced control over your private digital communications.

The Industry Connections

Woods’ role on the Family Online Safety Institute (FOSI) board reveals her deep connections to the surveillance-industrial complex (Family Online Safety Institute, 2025).

The Family Online Safety Institute (FOSI) actively brands itself as a champion for child safety but this public image is, in reality it functions as an industry body representing tech companies seeking to shape regulation in their favour.

FOSI’s marketing and website position it as a “non-profit” devoted to “making the online world safer for kids and families.” But examine its structure, funding, and influence, and a far more troubling pattern emerges:

FOSI is explicitly a membership-based trade association. Its own materials confirm that membership consists of technology, internet, IoT, and telecommunications companies and their trade associations. Individuals and public agencies cannot join. Members pay steep fees (as of 2025, $40,000 for large corporate members) in exchange for direct access to FOSI governance and events (FOSI, 2025).

FOSI is sustained by hefty membership fees (up to $40,000 per year for large corporate members) and by tech and telecom giants sponsoring its events and research. Its annual conferences are sponsored by Google, TikTok, Amazon, Netflix, Epic Games, Snap Inc., and many more (Qwoted, 2024; FOSI, 2025).

FOSI’s Board is stacked with senior executives from major tech companies:

  • VP, Civility & Partnerships, Roblox (FOSI Board Chair)
  • Head of Digital Safety, Verizon
  • Director, Global Technology & Innovation, Netflix
  • Child Safety Manager, Google
  • Senior Director of Public Policy, TikTok
  • Senior Director, Public Policy, Amazon
  • Director of User Trust & Online Safety, Nintendo of America
  • Director of Public Policy, Digital Safety, Microsoft
  • Vice President Policy Strategy, Disney

And many more spanning Uber, Walmart, Comcast, PlayStation/Sony, Snap Inc., and Tencent (FOSI, 2025).

FOSI’s annual conferences, forums, and research are consistently sponsored by major tech, telecom, and gaming companies. The 2024 Annual Conference, for example, listed:

  • Google and TikTok as “Diamond Sponsors”
  • Amazon and Epic Games as “Champion of Corporate Responsibility Sponsors”
  • Netflix, Resolver, PlayStation, Snap Inc., Roblox, Modulate, Uber and others as Gold/Silver sponsors (Qwoted, 2024).

Its 2025 European Forum was hosted at Netflix’s EMEA Headquarters and featured top corporate policy executives from Apple, Netflix, Epic Games, Google, TikTok and Microsoft alongside policymakers (FOSI, 2025).

FOSI calling itself a “child safety organisation” is gross because it weaponises public concern for vulnerable children to entrench Big Tech’s corporate power and agenda.

The world’s largest surveillance and data monetisation companies pay and staff FOSI, fund its events, and directly shape its lobbying strategy, all while hiding behind the rhetoric of family and child protection.

This duplicity is documented in FOSI’s membership rosters, event sponsor lists, and board biographies all of which are public on FOSI’s own website and related event pages. Every time FOSI is held up as a neutral “child safety” voice, it’s a PR victory for the very companies whose platforms profit from harvesting and manipulating the digital lives of families and children.

Woods’ academic credentials provide legitimacy to an organisation that helps corporations navigate regulatory frameworks, frameworks she helped design.

The OBE: Rewarding Surveillance Architecture

Woods received an OBE in 2020 “for her services to internet safety policy” (University of Essex, 2020). This was not awarded for protecting the public. It was awarded for producing the legal and policy framework of state surveillance powers.

Lorna Woods’ “duty of care” model was written into law almost verbatim, giving the UK government a regulatory instrument it had been seeking for years. Her work has created legal frameworks that enable mass monitoring of digital communications while claiming to protect children. Sad.

The Cognitive Dissonance

Woods academic writing critiques “over‑broad state surveillance” in abstract legal theory (Information Law & Policy Centre, 2015).

But her actions in regulatory practice speak louder, she engineers frameworks whose only enforceable form is the very surveillance she warns against.

  • She may believe that embedding “safeguards” in law will constrain misuse.
  • In practice, those safeguards are either unenforceable or quickly eroded in operational contexts, a classic case of policy naïvety in translating theory to implementation.

Her regulatory design appears rooted in pre‑platform era models of public safety law, where state inspection was physically bounded and resource‑limited.

  • In the networked era, regulation at the scale she demands can only be executed by automating suspicion, treating all users as potential rule‑breakers.
  • This reveals a short‑sightedness: failing to integrate technical reality into legislative drafting, and assuming law can be written as if the technology will obediently adapt.

However, this intellectual contradiction actually serves a purpose: it provides academic legitimacy to surveillance expansion by having a supposed “privacy expert” endorse it.

The Missing Opposition

Genuine digital rights organisations recognise Woods’ framework as authoritarian. Big Brother Watch, Open Rights Group, and Liberty consistently oppose the surveillance powers her work enables (GOV.UK, 2018).

She draws validation only from high‑status institutional affiliations like Carnegie UK, government advisory groups, industry‑adjacent “safety” boards.

  • This conflates elite endorsement with democratic legitimacy.
  • The dissonance: she critiques concentration of power in the surveillance state yet derives her policy authority from that same concentration.

The Revolving Door

After the Online Safety Act passed, Woods spun off the “Online Safety Act Network” with former Carnegie associate Maeve Walsh (Online Safety Act Network, 2024). This creates a permanent lobbying infrastructure continuing to influence policy implementation.

Walsh’s background reveals the institutional connections: she spent 17 years in Whitehall including roles in No. 10, Cabinet Office, and DCMS, where she “led the team responsible for delivering the UK Digital Strategy” (Online Safety Act Network, 2024).

This is the classic revolving door between government, academia, and advocacy organisations that characterises regulatory capture.

Maeve Walsh

A woman with shoulder-length brown hair, wearing a light gray blazer over a polka dot top, smiling against a plain white background.

Maeve Walsh represents the textbook case of how the “revolving door” between government and lobbying creates conflicts of interest that undermine democratic accountability. She spent 17 years as a senior civil servant, helped create the policy framework for online regulation while in government, then immediately cashed in on that insider knowledge by becoming a paid advocate for the very policies she helped design.

Bar graph illustrating Maeve Walsh's career trajectory, showing career phases in government service (2001-2017), transitions, policy advocacy (2018-2023), and lobbying, with notable exits indicated.

The 17-Year Government Insider

Walsh’s civil service career gave her unprecedented access to the levers of power and policy development (Online Safety Act Network, 2024):

Senior Government Positions:

  • Cabinet Office – the nerve center of UK government coordination
  • No. 10 Downing Street – direct access to Prime Ministerial decision-making
  • Department of Health – served as Principal Private Secretary to two Secretaries of State
  • DCMS (Department for Digital, Culture, Media & Sport) – led the team that developed the 2017 UK Digital Strategy

At DCMS, Walsh was specifically responsible for “delivering the UK Digital Strategy” (Online Safety Act Network, 2024) the foundational document that established the UK government’s approach to digital regulation and online safety.

The Seamless Transition to Lobbying

In 2018, just one year after leaving government, Walsh joined Carnegie UK Trust as an “Associate” (Carnegie UK Trust, 2023).

In her Carnegie role she has:

  • Co-authored the “duty of care” framework with Professor Lorna Woods and William Perrin
  • “Directly influenced the design and development of the Online Safety Bill” (Online Safety Act Network, 2024)
  • Convened “a large network of civil society campaigners and advocates”
  • Advised “Parliamentarians on all sides of the House”
  • Secured “significant concessions from the Government”

This is the language of lobbying, not independent policy research.

The Permanent Influence Infrastructure

When the Online Safety Act passed in 2023, Walsh didn’t retire, she created a permanent lobbying organisation to continue influencing its implementation (Online Safety Act Network, 2024).

The Online Safety Act Network:

  • Works with “over 70 organisations” to influence policy implementation (PoliticsUK, 2025)
  • Maintains direct contact with Ofcom, the regulator implementing the Act
  • Continues to advise parliamentarians on strengthening the legislation
  • Operates as a permanent lobbying infrastructure for digital regulation

Walsh openly describes her approach:

“Parliamentary scrutiny of the implementation of the Online Safety Act has stepped up a gear”

and celebrates how

“MPs voiced their discontent at the way the OSA’s implementation was progressing”

These comments are tone deaf. (PoliticsUK, 2025) .

The Conflict of Interest Problem

Walsh’s career trajectory creates multiple conflicts of interest:

  1. Policy Continuity: She helped design the UK’s digital strategy while in government, then immediately began advocating for specific implementations of that strategy through Carnegie UK.
  2. Inside Knowledge: Her 17 years in Whitehall, including time in No. 10 and the Cabinet Office, gave her insider knowledge of how to influence government decision-making that competitors and genuine civil society groups lack.
  3. Network Access: She maintains relationships with former colleagues still in government, creating informal influence channels unavailable to genuine outside advocates.
  4. Financial Incentives: As a “Carnegie Associate,” she was paid to influence policy (Carnegie UK Trust accounts show associates as paid positions). She now runs her own consulting company while directing the Online Safety Act Network.

The “Civil Servant in the Wild” Defence

Walsh describes herself as “a civil servant in the wild” (Civil Service World, 2024), presenting her lobbying work as public service rather than private interest advancement.

This framing obscures the fundamental conflict: she uses taxpayer-funded training, government networks, and insider knowledge to influence policy for private organisations. Her “civil servant” identity provides legitimacy while her “wild” status removes accountability.

The Democratic Deficit

Walsh’s career represents a fundamental threat to democratic accountability. She spent 17 years learning how government works, then immediately used that knowledge to influence the same processes for private interests.

The Problems:

  • Unequal Access: Genuine civil society groups can’t compete with someone who has insider knowledge and networks
  • Policy Capture: The same person shapes policy from inside government, then shapes its implementation from outside
  • Accountability Gap: She faces no electoral accountability for her influence over democratic processes
  • Conflict of Interest: She profits from influencing policies she helped create while in government

William Perrin

A smiling man with glasses, wearing a checked shirt, against a dark background with colorful icons.

William Perrin represents textbook regulatory capture. He is another former senior civil servant who spent over a decade creating the UK’s regulatory frameworks, then immediately leveraged that insider knowledge to influence the very systems he designed while in government.

Perrin’s 12-year civil service career gave him unparalleled access to the machinery of government regulation and policy-making:

He was the Technology Policy Advisor to Prime Minister Tony Blair (2001-2004) which gave him direct access to the highest levels of government decision-making (Indigo Trust, 2023)

He was the Deputy Director Strategy and Policy, Cabinet Office (2005-2008) a central coordination role across all government departments (LinkedIn, 2025)

He was the Secretary to Power of Information Taskforce (2008-2009)** and designed the UK’s open data strategy (LinkedIn, 2025)

He was instrumental in creating OFCOM the media and telecommunications regulator (RSA, 2024)

He authored the UK’s first government IT strategy in over 20 years (Alpha.gov.uk, 2012)

None of this was innocent policy advice these project trace Perrin’s involvement with the fundamental architecture building for UK regulation across multiple sectors.

The Immediate Monetisation (2008-2018)

Perrin left government in 2008 and immediately began monetizing his insider knowledge:

Described himself as providing “consultancy services to some of the world’s leading technology and media companies” (RSA, 2024)

Funded by Google (the same tech giant that would later be subject to the online safety regulations he helped design) (RSA, 2024)

Digital Advisory Board, Government Digital Service (2012-2014) advising the same government he’d left (LinkedIn, 2025)

Advisory Board Member, Digital Government Review (2014-2015)** – continuing influence over government digital strategy (LinkedIn, 2025)

This shows the classic revolving door pattern: leave government, immediately start advising the same government you just left.

In 2018, Perrin joined Carnegie UK Trust as a trustee and began his most sophisticated influence operation:

The Online Safety Framework

Working with Professor Lorna Woods, Perrin developed the “duty of care” framework that became the foundation of the UK’s Online Safety Act (Carnegie UK Trust, 2018).

Perrin was awarded an OBE in 2020 “for services to Technology and Internet Safety Policy” (LinkedIn, 2025).

However much like Woods, this government honour for work that influenced government policy represents a clear conflict of interest being rewarded by the same system he was trying to influence.

The Multiple Conflicts of Interest

Perrin’s career creates layered conflicts of interest:

  • Regulatory Architecture: He helped create OFCOM while in government, then developed online safety frameworks that expanded OFCOM’s powers through Carnegie UK.
  • Google Funding: His startup received Google funding, then he helped design regulations that would affect Google and other tech companies.
  • Government Networks: He maintains relationships with former colleagues still in government, creating informal influence channels.
  • Advisory Roles: He continued advising government bodies even after leaving, blurring the line between public service and private interest.

The Expertise Myth

Perrin is often presented as bringing “expertise” to policy debates. But his expertise isn’t in technology (clearly) it’s specifically in how to manipulate the regulatory systems he helped create.

His 2018 LSE blog post with Lorna Woods reveals this clearly: they didn’t start from research on online harms, they started from existing regulatory models and looked for ways to apply them to social media (LSE, 2018).

This is regulation-seeking-a-problem, not problem-seeking-a-solution.

The fact that he’s celebrated rather than scrutinised for this career path shows how normalised regulatory capture has become in British governance. This should deeply trouble anyone who doesn’t want their children to ‘be next’.

When former civil servants can seamlessly transition to influencing their former colleagues while maintaining the appearance of public service, the boundary between democratic governance and private lobbying disappears entirely.

The Consultation That Never Happened

The Online Safety Act reads like a law written in a vacuum. Its architecture shows no trace of serious engagement with legal‑tech experts, new‑generation internet users, or platform engineers who understand how online systems actually work.

There is no evidence that its designers sought to interrogate the technical feasibility of their own framework with those who would be tasked with implementing it.

Children’s rights and digital literacy organisations have publicly condemned the Act for undermining young people’s rights, chilling expression, and replacing education with censorship.

Regulatory and human rights experts have called the Act incoherent. Former regulators, freedom‑of‑expression advocates, and digital rights law specialists warn that the duty of care model is structurally incompatible with privacy‑preserving design.

The Information Commissioner’s Office itself flagged risks to encryption and personal data rights during the Bill’s passage.

Even big tech, which usually adapts to regulation with minimal complaint, has issued formal warnings. Meta, Apple, and Signal have publicly opposed provisions requiring access to encrypted communications. WhatsApp threatened to withdraw UK service rather than comply with clauses that would mandate client‑side scanning. These are loud statements from supposed supporters about technical impossibility and rights violations presented here.

This breadth of opposition exposes the ignorance baked into Carnegie’s model. A credible lawmaking process would have treated these constituencies as primary stakeholders. Instead, Carnegie UK and Lorna Woods advanced a closed‑door policy, reinforced by a hand‑picked coalition of agreeable partners, and ignored dissent until after the law was passed.

The result is a regulatory instrument that satisfies neither its stated objectives nor its practical realities. It cannot deliver genuine online safety. It alienates those it claims to protect. It hands Ofcom powers that are unusable without building a surveillance apparatus the public does not consent to. This is not a design flaw that can be tweaked it is proof that the Act was conceived without the expertise or lived experience of the communities it purports to serve.

Consultation Vacuum

The Online Safety Act moved from White Paper to statute without structured engagement with the communities that must implement it, live with it, or be protected by it. There is no record in Parliamentary or Home Office evidence sessions of platform security engineers being consulted (ARTICLE 19 et al., 2022). Encryption specialists warned that the Bill would destroy end-to-end encryption and were ignored (Signal, 2023). Research found youth voices notable by their absence from deliberations (Internet Matters, 2022). Children’s rights organisations, including the 5Rights Foundation, warned that the Bill is unworkable, risks driving abuse underground and fails to provide robust protections (5Rights Foundation, 2022). Independent digital rights lawyers described it as incoherent and incompatible with rule-of-law standards (ARTICLE 19, 2021).

Technical Feasibility Warnings

Encrypted messaging providers stated that clauses mandating client-side scanning were technically unworkable and would trigger service withdrawal. Signal called the regime mass surveillance incompatible with safety (Signal, 2023). The Information Commissioner’s Office warned that undermining encryption would reduce child safety by exposing data to breach risk (ICO, 2021).

Encrypted messaging services have recently issued stark warnings about the UK’s Online Safety Act. WhatsApp publicly stated it will leave the UK if required to weaken its end-to-end encryption, saying client-side scanning requirements undermine both security and trust (The Verge, 2023). Signal and other secure messaging providers also signed an open letter calling clause 122 an “unprecedented threat” to privacy and user safety, warning the government to reconsider its approach (The Independent, 2023).

The government has since admitted that the technology required to scan encrypted messages in a privacy-preserving way does not exist and has effectively paused enforcement of that provision (Wired, 2023).

Despite these warnings, the Act still empowers Ofcom to require proactive content scanning, a task that can only be delivered by building large-scale surveillance infrastructure.

Youth and Child-Sector Opposition

Internet Matters’ “Our Voice Matters” survey of 14 to 18-year-olds reported that adolescents felt sidelined even though the Bill claimed to prioritise them (Internet Matters, 2022). YoungMinds urged legislators to integrate youth-led mental health evidence but its recommendations were excluded from successive drafts (YoungMinds, 2024). The 5Rights Foundation warned that the Act risks undermining trust between young users and platforms (5Rights Foundation, 2022).

Civil-Society and Regulatory Critique

A coalition including Big Brother Watch, Index on Censorship, Open Rights Group and Liberty labelled the Act the greatest threat to freedom of expression in a generation (ARTICLE 19 et al., 2022). The ICO warned that over-broad scanning powers would disproportionately impact lawful users (ICO, 2021).

Industry Pushback

Apple, Meta, Signal and five other providers sent an open letter to the UK government stating that clause 122 creates an unprecedented regime of mass surveillance (EFF, 2023). TechRadar reported a 1,400% spike in UK VPN sign-ups within a week of age-verification rules taking effect, signalling widespread user rejection (TechRadar, 2025).

Pattern

The design originated in a closed circle of Carnegie UK and Lorna Woods with no systems engineers present. Consultation excluded encryption specialists, safety-tech engineers and young users. Warnings from every technical and rights-based constituency are on record in public submissions. Legislators adopted the framework regardless, producing a statute that requires surveillance capabilities the UK tech stack cannot lawfully or reliably deliver.

Result

The Act now faces operational gridlock as scanning mandates collide with encryption mathematics. It faces legal uncertainty with privacy and rights challenges in preparation. It faces popular backlash with over 490,000 repeal signatures (as of 5pm 4 aug 25). Sign it here please: petition.parliament.uk/petitions/722903

This is the product of a consultation failure measurable across every expert domain required for its success.

Why Carnegie UK’s Public Admissions Aren’t “Positive Influence”, They’re Clear Signs of Regulatory Capture

To understand why it’s alarming for a century-old billionaire endowment to say things like:

“We are pleased that the UK government has adopted in part our approach” (Carnegie UK, 2024)

“Our work has influenced the recommendations of a number of bodies” (Carnegie UK, 2019)

“Our work was repeatedly cited in debates by Parliamentarians” (Carnegie UK, 2024)

You need to see how real democracy is supposed to work, and why what happened here is an example of regulatory capture.

Democracy Means Laws Are Made by Elected Representatives, For the Public

In a healthy democracy, laws get made through open debate, evidence from many different sources, and decisions by people who are accountable to the public, namely, elected MPs.

When a private, billionaire-funded group drafts laws behind the scenes, and Parliament just signs off, that’s not democracy, that’s power working through the back door. That is regulatory capture. The process looks official, but the real choices were made long before any public debate (Carnegie UK, 2024).

Regulatory Capture: When Industry and Private Wealth Write the Rules

Regulatory capture is what happens when regulatory agencies or Parliament start doing what powerful private interests want, instead of acting for the public.

Carnegie UK provided the blueprint, supplied “oven-ready” laws, and used its staff and money to push those ideas until they became government policy (Carnegie UK, 2024). They were both the authors and the cheerleaders. When regulators and lawmakers let this happen, the system is captured.

Old Money, Old Influence – Still a Problem

Some people may argue:

“But the Carnegie Trust is over 100 years old—doesn’t that make it a historic part of British life, not something sinister?”

In fact, the age of this billionaire endowment is precisely why its power is so normalised. Corruption and influence can become traditions if left unchallenged. The origin of their money is violence, exploitation, and monopoly and that hasn’t gotten less toxic just because it’s old. Nor does time erase the reality that unelected, unaccountable, privately-funded groups should NOT get to write public law (OSCR, 2021).

Why Their Admissions are Alarming

When Carnegie UK says Parliament “adopted in part our approach,” that’s not a humble brag. It’s the legal equivalent of seeing a fox in the henhouse and having the fox proudly announce, “You let me design the coop!”

Every time they say their work was “repeatedly cited by Parliamentarians,” it should trouble you. This it’s not a sign of healthy debate it’s a sign the debate never left the boundaries they set. Their funding power and policy-making muscle worked exactly as designed.

The Time for Accountability is Now

Just because this style of “philanthropic capture” has been happening for decades (or centuries) doesn’t make it right. It only means we’re overdue for much stricter transparency and democratic control. If ordinary people can’t see, let alone influence, how laws get made, then democracy is a hollow shell not worth preserving. Is it fair that those with permanent money make the permanent rules?

To defend real democracy, we have to stop confusing charitable influence with public interest, and start demanding accountability from any group old or new, rich or poor that wants influence to write the laws that govern us all.

A billionaire foundation openly boasting about writing major public law while escaping public scrutiny is not an inspiring success story.

It’s actually really embarrassing for the British establishment (or what’s left of it).

This entire fiasco has been a textbook definition of regulatory capture and proof that wealth and power never lose their appetite to govern in private.

Let’s not confuse tradition with legitimacy, nor private philanthropy with public accountability.

Sign the Repeal the Online Safety Act

petition.parliament.uk/petitions/722903

This Substack is reader-supported. To receive new posts and support my work, consider becoming a free or paid subscriber.

Sources

AFL-CIO. (2023). ‘1892 Homestead Strike’. Available at: https://aflcio.org/about/history/labor-history-events/1892-homestead-strike (Accessed: 4 August 2025).

Alpha.gov.uk. (2012). ‘Digital Advisory Board profile – Will Perrin’. Available at: https://alphagov.wordpress.com/profilewillperrin/ (Accessed: 4 August 2025).

ARTICLE 19. (2021). ‘UK: Online Safety Bill threatens freedom of expression’. Available at: https://www.article19.org/resources/uk-online-safety-bill-freedom-expression/ (Accessed: 4 August 2025).

ARTICLE 19 et al. (2022). ‘Joint civil society response to the Online Safety Bill’. Available at: https://www.article19.org/resources/uk-joint-civil-society-response-online-safety-bill/ (Accessed: 4 August 2025).

Bill of Rights Institute. (2025). ‘Andrew Carnegie Steel Tycoon Industry’. Available at: https://billofrightsinstitute.org/essays/andrew-carnegie-and-the-creation-of-us-steel (Accessed: 4 August 2025).

Bill of Rights Institute. (2025). ‘Homestead Strike, labor unions, steel industry, Andrew Carnegie’. Available at: https://billofrightsinstitute.org/essays/the-homestead-strike (Accessed: 4 August 2025).

Britannica. (2025). ‘Carnegie Steel Company | Corporation, History, Description, & Facts’. Available at: https://www.britannica.com/money/carnegie-steel-company (Accessed: 4 August 2025).

Britannica. (2014). ‘Homestead Strike | Summary & Significance’. Available at: https://www.britannica.com/event/homestead-strike (Accessed: 4 August 2025).

Carnegie UK Trust. (2019). ‘Carnegie Trust Response – GOV.UK’. Available at: https://assets.publishing.service.gov.uk/media/5d762acd40f0b60924db6695/20190730__Carnegie_Trust_-Response_to_SoS-_non-confidential_version.pdf (Accessed: 4 August 2025).

Carnegie UK Trust. (2024). ‘Annual Report and Accounts 2024 Final’. Available at: https://carnegieuk.org/wp-content/uploads/2025/06/Annual-Report-and-Accounts-2024-Final.pdf (Accessed: 4 August 2025).

Carnegie UK Trust. (2024). ‘Draft Online Harm Reduction Bill’. Available at: https://carnegieuk.org/publication/draft-online-harm-reduction-bill/ (Accessed: 4 August 2025).

Carnegie UK Trust. (2024). ‘Online harms resource page’. Available at: https://carnegieuk.org/online-harms-resource-page/ (Accessed: 4 August 2025).

Carnegie UK Trust. (2024). ‘Tackling Online Harms’. Available at: https://carnegieuk.org/programmes/online-harms/ (Accessed: 4 August 2025).

Carnegie UK Trust. (2024). ‘The Draft Online Safety Bill: Carnegie UK Trust initial analysis’. Available at: https://carnegieuk.org/blog/the-draft-online-safety-bill-carnegie-uk-trust-initial-analysis/ (Accessed: 4 August 2025).

Carnegie UK Trust. (2023). ‘Annual report and accounts 31 December 2023’. Available at: https://carnegieuk.org/wp-content/uploads/2024/10/Annual-report-and-accounts-31-December-2023-2.pdf (Accessed: 4 August 2025).

Centre for International Governance Innovation. (2021). ‘What Can Canadian Law Makers Draw from the New UK Online Safety Bill?’. Available at: https://www.cigionline.org/articles/what-can-canadian-law-makers-draw-new-uk-online-safety-bill/ (Accessed: 4 August 2025).

Civil Service World. (2024). ‘Meet Maeve Walsh: The ‘civil servant in the wild’ who fought for the Online Safety Act’. Available at: https://www.civilserviceworld.com/in-depth/article/meet-maeve-walsh-the-civil-servant-in-the-wild-who-fought-for-the-online-safety-act (Accessed: 4 August 2025).

Decentered. (2025). ‘Should Ofcom Be Abolished or Reformed? A Case for Pragmatic Regulation’. Available at: https://decentered.co.uk/should-ofcom-be-abolished-or-reformed-a-case-for-pragmatic-regulation/ (Accessed: 4 August 2025).

Derbyshire Times. (2025). ‘Over 300,000 sign petition calling for repeal of Online Safety Act’. Available at: https://www.derbyshiretimes.co.uk/news/politics/over-300000-sign-petition-calling-for-repeal-of-online-safety-act-4567890 (Accessed: 4 August 2025).

Digital Public Library of America. (2016). ‘The Homestead Strike’. Available at: https://dp.la/primary-source-sets/the-homestead-strike (Accessed: 4 August 2025).

EFF. (2023). ‘UK’s Online Safety Bill: An Unprecedented Threat to Global Privacy and Free Expression’. Available at: https://www.eff.org/deeplinks/2023/07/uks-online-safety-bill-unprecedented-threat-global-privacy-and-free-expression (Accessed: 4 August 2025).

Family Online Safety Institute. (2025). ‘Lorna Woods’. Available at: https://fosi.org/people/lorna-woods/ (Accessed: 4 August 2025).

Family Online Safety Institute. (2025). ‘Membership’. Available at: https://fosi.org/membership/ (Accessed: 4 August 2025).

5Rights Foundation. (2022). ‘Response to Online Safety Bill’. Available at: https://5rightsfoundation.com/uploads/5Rights-Foundation-response-to-Online-Safety-Bill-June-2022.pdf (Accessed: 4 August 2025).

GOV.UK. (2018). ‘Automatic Number Plate Recognition (ANPR) – National Advisory Group Minutes’. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/731164/ANPRIAG_Minutes_17-01-18.pdf (Accessed: 4 August 2025).

GOV.UK. (2025). ‘Online Safety Act: explainer’. Available at: https://www.gov.uk/government/publications/online-safety-act-explainer/online-safety-act-explainer (Accessed: 4 August 2025).

GOV.UK. (2025). ‘Secretary of State speech to FOSI annual conference’. Available at: https://www.gov.uk/government/speeches/secretary-of-state-speech-to-fosi-annual-conference (Accessed: 4 August 2025).

ICO. (2021). ‘Age appropriate design code consultation response’. Available at: https://ico.org.uk/about-the-ico/news-and-events/news-and-blogs/2021/03/ico-publishes-age-appropriate-design-code/ (Accessed: 4 August 2025).

Indigo Trust. (2023). ‘William Perrin OBE’. Available at: https://indigotrust.org.uk/about-us/williamperrin/ (Accessed: 4 August 2025).

Information Law & Policy Centre. (2015). ‘Lorna Woods: Schrems v Data Protection Commissioner’. Available at: https://infolawcentre.blogs.sas.ac.uk/2015/09/23/lorna-woods-schrems-v-data-protection-commissioner-the-beginning-of-the-end-for-safe-harbour/ (Accessed: 4 August 2025).

The Independent. (2023). ‘WhatsApp and Signal threaten to quit UK over Online Safety Bill’. Available at: https://www.independent.co.uk/tech/whatsapp-signal-uk-online-safety-bill-b2399294.html (Accessed: 4 August 2025).

Internet Matters. (2022). ‘Our Voice Matters: Young people’s views on the Online Safety Bill’. Available at: https://www.internetmatters.org/hub/research/our-voice-matters-report/ (Accessed: 4 August 2025).

Internet Public Library. (2023). ‘Andrew Carnegie Dbq’. Available at: https://www.ipl.org/essay/andrew-carnegie-dbq-fe6dca4a9d25fbcb (Accessed: 4 August 2025).

Internet Public Library. (2023). ‘Was Andrew Carnegie A Robber Baron Or A Captain Of Industry’. Available at: https://www.ipl.org/essay/was-andrew-carnegie-a-robber-baron-or-43c9c6d39c0c529b (Accessed: 4 August 2025).

Left Foot Forward. (2024). ‘Ofcom: Who watches the watchdog?’. Available at: https://leftfootforward.org/2024/07/ofcom-who-watches-the-watchdog/ (Accessed: 4 August 2025).

LinkedIn. (2025). ‘William Perrin OBE FRSA – Carnegie UK Trust’. Available at: https://uk.linkedin.com/in/wperrin (Accessed: 4 August 2025).

LSE. (2018). ‘Which social media services should be regulated for harm reduction?’. Available at: https://blogs.lse.ac.uk/medialse/2018/05/10/which-social-media-services-should-be-regulated-for-harm-reduction/ (Accessed: 4 August 2025).

MacArthur Foundation. (2013). ‘Family Online Safety Institute’. Available at: https://www.macfound.org/grantee/family-online-safety-institute-45089/ (Accessed: 4 August 2025).

Melbado. (2025). ‘How Did Andrew Carnegie Treat His Workers?’. Available at: https://melbado.com/how-did-andrew-carnegie-treat-his-workers/ (Accessed: 4 August 2025).

Metal Forming Solutions. (2019). ‘Safety In The Steel Industry’. Available at: https://metalformingsolutions.com/pipe-bending/safety-in-the-steel-industry/ (Accessed: 4 August 2025).

Online Safety Act Network. (2024). ‘About us’. Available at: https://www.onlinesafetyact.net/about/ (Accessed: 4 August 2025).

OSCR. (2021). ‘Carnegie United Kingdom Trust – OSCR | Charity Details’. Available at: https://www.oscr.org.uk/about-charities/search-the-register/charity-details?number=sc012799 (Accessed: 4 August 2025).

Paul Bernal’s Blog. (2015). ‘Open letter on rule of law and surveillance’. Available at: https://paulbernal.wordpress.com/2015/05/26/open-letter-on-rule-of-law-and-surveillance/ (Accessed: 4 August 2025).

PBS American Experience. (2017). ‘The Steel Business’. Available at: https://www.pbs.org/wgbh/americanexperience/features/carnegie-steel-business/ (Accessed: 4 August 2025).

PBS American Experience. (2017). ‘The Strike at Homestead Mill’. Available at: https://www.pbs.org/wgbh/americanexperience/features/carnegie-strike-homestead-mill/ (Accessed: 4 August 2025).

PolicyReview. (2023). ‘Regulatory capacity capture: the United Kingdom’s online safety regime’. Available at: https://policyreview.info/articles/analysis/regulatory-capacity-capture-united-kingdoms-online-safety-regime (Accessed: 4 August 2025).

Politics Home. (2025). ‘Women in Westminster – Politics Home’. Available at: https://www.politicshome.com/in-focus/wiw.htm (Accessed: 4 August 2025).

PoliticsUK. (2025). ‘Online Safety Act Implementation: Parliament Steps Up Its Scrutiny’. Available at: https://politicsuk.com/online-safety-act-implementation/ (Accessed: 4 August 2025).

Qwoted. (2024). ‘FOSI Annual Conference 2024’. Available at: https://app.qwoted.com/opportunities/event-fosi-annual-conference-2024 (Accessed: 4 August 2025).

RSA. (2024). ‘William Perrin’. Available at: https://www.thersa.org/people/william-perrin/ (Accessed: 4 August 2025).

Signal. (2023). ‘UK’s Online Safety Bill: Global Privacy Under Threat’. Available at: https://signal.org/blog/uk-online-safety-bill-analysis/ (Accessed: 4 August 2025).

TechCrunch. (2014). ‘UK Emergency Surveillance Law Criticized For Being Overly Broad, Vague And Draconian’. Available at: https://techcrunch.com/2014/07/15/uk-emergency-surveillance-law-criticized-for-being-overly-broad-vague-and-draconian/ (Accessed: 4 August 2025).

Technology and Regulation. (2019). ‘Online harm reduction – a statutory duty of care and regulator’. Available at: https://techreg.org/article/download/10987/11961/20668 (Accessed: 4 August 2025).

TechRadar. (2025). ‘UK VPN sign-ups spike 1,400% following Online Safety Act enforcement’. Available at: https://www.techradar.com/vpn/uk-vpn-signups-spike-following-online-safety-act (Accessed: 4 August 2025).

University of Essex. (2020). ‘Professor Lorna Woods to receive OBE for research on internet safety and online harms’. Available at: https://www.essex.ac.uk/news/2020/10/13/professor-lorna-woods-to-receive-obe-for-research-on-internet-safety-and-online-harms (Accessed: 4 August 2025).

University of Essex. (2023). ‘Lorna Woods praised in Lords’. Available at: https://www.essex.ac.uk/news/2023/09/26/lorna-woods-praised-in-lords (Accessed: 4 August 2025).

University of Essex. (2018). ‘Lorna Woods’. Available at: https://www.essex.ac.uk/people/woods91406/lorna-woods (Accessed: 4 August 2025).

The Verge. (2023). ‘WhatsApp will leave the UK if forced to break encryption, says boss’. Available at: https://www.theverge.com/2023/5/16/23725197/whatsapp-will-leave-the-uk-if-forced-to-break-encryption-says-boss (Accessed: 4 August 2025).

Wikipedia. (2003). ‘Homestead strike’. Available at: https://en.wikipedia.org/wiki/homestead_strike (Accessed: 4 August 2025).

Wikipedia. (2008). ‘Family Online Safety Institute’. Available at: https://en.wikipedia.org/wiki/family_online_safety_institute (Accessed: 4 August 2025).

Wikipedia. (2009). ‘Carnegie United Kingdom Trust’. Available at: https://en.wikipedia.org/wiki/carnegie_united_kingdom_trust (Accessed: 4 August 2025).

Wikipedia. (2021). ‘Online Safety Act 2023’. Available at: https://en.wikipedia.org/wiki/online_safety_act 2023 (Accessed: 4 August 2025).

Wired. (2023). ‘The UK Admits Defeat on Encryption’. Available at: https://www.wired.com/story/uk-admits-defeat-encryption/ (Accessed: 4 August 2025).

YoungMinds. (2024). ‘Online Safety Bill: YoungMinds response’. Available at: https://www.youngminds.org.uk/about-us/policy-work/policy-responses/online-safety-bill-youngminds-response/ (Accessed: 4 August 2025).

Zinn Education Project. (2024). ‘July 6, 1892: Homestead Strike’. Available at: https://www.zinnedproject.org/news/tdih/homestead-strike/ (Accessed: 4 August 2025).


Comments

Leave a Reply